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OECD Unique Identifier details

BCS-GHØØ2-5
Commodity: Cotton
Traits: Glyphosate tolerance
European Union
Name of product applicant: Bayer
Summary of application:

The genetically modified BCS-GHØØ2-5 cotton, as described in the application, expresses the 2mEPSPS protein which confers tolerance to glyphosate herbicides.

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Date of authorization: 17/06/2011
Scope of authorization: Food and feed
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.): Biosafety Clearing House (BCH)
OECD BioTrack Product Database
Summary of the safety assessment (food safety):
Please see the EU relevant links below.
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Event specific real-time quantitative PCR based method for genetically modified cotton BCS-GHØØ2-5. - Validated by the Community reference laboratory established under Regulation (EC) No 1829/2003. Please see the EU relevant links below.
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment: Opinion of the European Food Safety Authority
Method for Detection
Reference Material (AOCS 1108-A and AOCS 0306-A)
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Authorization expiration date (a blank field means there is no expiration date) 16/6/2021
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Organization/agency name (Full name):
European Union
Contact person name:
Alexandre Huchelmann
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Physical full address:
European Commission B232 04/106 1047 Brussels
Phone number:
3222954092
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Country introduction:

The process for authorising a new GMO is based on the EU regulation on GM food and feed (1829/2003). An application for authorising food or feed consisting of or made from a GMO must be submitted to the national authorities. The national authority then sends the application to the European Food Safety Agency (EFSA) for a risk assessment. EFSA then makes the application summary available to the public. No matter where in the EU the company applies, EFSA assesses the risks the GMO presents for the environment, human health and animal safety. If the application covers cultivation, EFSA delegates the environmental risk assessment to an EU country which sends EFSA its risk assessment report. After performing the risk assessment, EFSA submits its scientific opinion to the European Commission and to EU countries. The opinion is made available to the public, except for certain confidential aspects. Once EFSA publishes its risk assessment, the public has 30 days to comment on the Commission website for applications under Reg. 1829/2003, and on the Joint Research Centre website on the assessment report of the "lead" EU country for applications under Directive 2001/18. Within 3 months of receiving EFSA's opinion, the Commission grants or refuses the authorisation in a proposal. If it differs from EFSA’s opinion, it must explain why. National representatives approve the Commission’s proposal by qualified majority in: (1) The Standing Committee on the Food Chain and Animal Health if the application was submitted under Reg. 1829/2003; (2) The Regulatory Committee under Directive 2001/18/EC if the application was submitted under Dir. 2001/18. The proposal is adopted if the Committee agrees with it. If there is no opinion, the Commission may summon an Appeal Committee where EU countries can adopt or reject the proposal. If the Appeal Committee makes no decision, the Commission may adopt its proposal. Authorisations are valid for 10 years (renewable).

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Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:
Australia
Name of product applicant: Bayer CropScience Pty Ltd
Summary of application:
Glyphosate (N-phosphonomethylglycine) is a non-selective, broad spectrum herbicide. The mode of action of glyphosate is to specifically bind to, and block, the activity of a native plant enzyme, 5-enol-pyruvylshikimate-3-phosphate synthase (EPSPS). EPSPS is a key enzyme in the shikimate pathway in plants which links the metabolism of carbohydrates to the biosynthesis of ring-containing compounds including aromatic amino acids. Plant EPSPS enzymes are normally inactivated by glyphosate which leads to cellular deficiencies in certain amino acids resulting ultimately in the death of the plant.
In cotton line GHB614, tolerance to glyphosate is achieved through expression in the plant of a modified form of the EPSPS enzyme, 2mEPSPS, derived from corn. Two point (single nucleotide) mutations were introduced to the corn epsps gene to generate 2mepsps, using site directed mutagenesis. These changes significantly reduce the sensitivity of the 2mEPSPS enzyme to glyphosate, allowing it to continue to function in the presence of the herbicide.
Cotton line GHB614 has been developed for agriculture in major cotton producing countries worldwide, including Australia.
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Date of authorization: 17/09/2009
Scope of authorization: Food
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.): OECD BioTrack Product Database
Summary of the safety assessment (food safety):
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment: Application A614 - Food Derived From Glyphosate-Tolerant Cotton Line GHB614
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Authorization expiration date (a blank field means there is no expiration date)
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Organization/agency name (Full name):
Food Standards Australia New Zealand
Contact person name:
Gaya Subramaniam
Website:
Physical full address:
Level 4, 15 Lancaster Place, Majura Park ACT 2609, Australia
Phone number:
+61 2 6271 2222
Fax number:
+61 2 6271 2278
Country introduction:

Food Standards Australia New Zealand (FSANZ) is the regulatory agency responsible for the development of food standards in Australia and New Zealand. The main office (approximately 115 staff) is located in Canberra (in the Australian Capital Territory) and the smaller New Zealand office (approximately 10 staff) is located in Wellington on the North Island.

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Stacked events:

FSANZ does not: Separately assess food from stacked event lines where food from the GM parents has already been approved; Mandate notification of stacked events by developers; Notify the public of stacked event ‘approvals’; List food derived from stacked event lines in the Code, unless the stacked event line has been separately assessed as a single line e.g. Application A518: MXB-13 cotton (DAS-21023-5 x DAS-24236-5)

No separate approval or safety assessment is necessary for foods derived from a stacked GM line that is the result of traditional breeding between a number of GM parent lines for which food has already been approved. Food from the parent lines must be listed in the Australia New Zealand Food Standards Code. The parent lines may contain any number of different genes. If food from any of the GM parent lines has not been approved, then a full pre-market safety assessment of food from the stacked line must be undertaken.

No separate approval is required for food derived from a line that is the product of a GM line, for which food has been approved, crossed traditionally with a non-GM line.

Where a single line containing a number of genes has been produced as a result of direct gene technology methods (rather than traditional crossing) then food derived from the line must undergo a full pre-market safety assessment before approval can be given

Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Food Standards Australia New Zealand (FSANZ) (http://www.foodstandards.gov.au)

Brazil
Name of product applicant: Bayer S.A
Summary of application:
Commercial release of of genetically modified herbicide tolerant cotton styled GHB614 (GlyTol® Cotton)
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Date of authorization: 09/12/2010
Scope of authorization: Food and feed
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.): Center for Environmental Risk Assessment
Summary of the safety assessment (food safety):
Event GHB614 was obtained through transformation of a variety of Coker 312 cotton, the genetic modification of which took place through a system mediated by Agrobacterium tumefasciens for the insertion of gene 2mepsps, responsible for expression of enzyme 2mEPSPS (5-enolpyruvylshikimate-3-phosphate synthase) by changing just two amino acids in the original peptide sequence. The enzyme grants GlyTol® cotton selectivity to herbicides containing the active ingredient glyphosate, therefore enabling to control pest plants in the crop post-emergence without harming the culture of the genetically modified cotton. Safety assessments conducted with GHB614 cotton showed alimentary innocuity, similarly to the parent conventional plants (var. Coker312). Regarding safety studies, assessments were conducted to determine whether GlyTol® cotton is similar to other cotton varieties regarding its use in human/animal feeding. Several studies were carried out of molecular characterization, expression of 2mEPSPS protein indifferent tissues, nutritional/compositional analysis, animal nutrition, protein digestibility, protein acute toxicity, and protein homology with toxic/allergenic compounds. Results in each case indicated that GHB614 and its progeny are substantially equivalent to other cotton varieties. The inserted DNA, as well as the expressed 2mEPSPS protein, fails to offer significant risk to human/animal health comparatively to the use of conventional cotton and byproducts in food. Aspects of environmental safety were assessed in a number of studies conducted in the national territory on the fields where it remained proved that plants derived from event GHB614 display the same agronomic behavior and adaptability in comparison with conventional genotypes, with no change of characters regulating the species survival and reproduction. Comparative analyses of morphological, phenotypic, and agronomic characteristics showed that none of the variables was changed as a result of inserting 2mepsps gene. Besides, no character was recorded that could grant selective advantage to GlyTol® or atypical behavior to the species. Regarding possible risks to the environment, issues related to endemic distribution of the feral form of G. mustelinum were considered and assessed in the south of Rio Grande do Norte and northeast of Bahia, and sub-spontaneous forms of G. barbadense in the Amazon region, Pantanal, southeast of Piauí and west of Pernambuco, as well as in the Atlantic forest, corresponding to the states of RN, PB, AL, SE, BA, MG and ES. Specificity to tolerance to the glyphosate herbicide was tested in the fields when the plants were submitted to the action of ammonium gluphosinate, resulting in total destruction of the plants so treated. Analyses of morphological, phenotypic and agronomic characteristics failed to evidence any difference between the genetically modified and non-genetically modified cotton, and no parameters were recorded that could grant selective advantages to GHB614 cotton or atypical behavior to the species. Besides, CTNBio searched the independent scientific literature to assess occurrence of any unexpected effect from the crossing between the events. Under Article 14 of Law nº 11,105/05, CTNBio held that the request complies with the applicable rules and legislation aimed at securing safety of the environment, agriculture, and human and animal health, and concluded that GHB614 cotton (GlyTol® cotton) is substantially equivalent to conventional cotton, being its consumption safe for human and animal health. Regarding the environment, CTNBio concluded that farming of GHB614 cotton (GlyTol® cotton) is not a potential cause of significant degradation to the environment, keeping with the biota a relation identical to that of the conventional cotton. CTNBio TECHNICAL OPINION I. Identification of GMO Name of GMO: GlyTol® cotton, Event GHB614 Applicant: Bayer S.A. Species: Gossypium hirsutum L. Inserted Characteristics: Tolerance to glyphosate Method of insertion: Transformation mediated by Agrobacterium tumefaciens containing vector pTEM2 Proposed use: Production of fibers for the textile industry and grain for human and animal consumption from the GMO and its derivatives II. General Information Cotton belongs to genus Gossypium, Tribe Gossypiae, Family Malvaceae, order Malvales (FRYXELL, P.A. 1979; MUNRO, J.M. 1987). The genus is divided into four sub-genera (Gossypium, Sturtia, Houzingenia and Karpas) that, in turn, are subdivided into nine sections and several sub-sections (FRYXELL, P.A.; CRAVEN, L.A.; and STEWART, J.MCD. 1992). Genus Gossipyum currently encompasses 52 species distributed in Asia, Africa, Australia and America, of which only 4 are cultivated. Gossypium arboretum L., cultivated in India is commercially important, and Gossypium herbaceum L., which was more important in the past, is currently planted just in some dry regions of Africa and Asia. Finally, about 90% of the world population of cotton belongs to Gossypium hirsutum and 8% to Gossypium barbadense (LEE, 1984). Out of the over 50 species already listed, all have a basic chromosome number n= 13, in which one part is diploid (2n+ 26), such as the cotton plants of the Old World (Africa and Asia), endemic species of Australia (CRAVEN et al., 1994) and some species of America. Other cotton species are tetraploid (allotetraploid), with n= 2x13= 26 and 2n= 52, involving, according to FRYXELL (1984), six species: G. tomentosum, endemic in Hawaii, G. mustelinum, in the Brazilian northeast, G. darwinii, in the Galapagos archipelago, G. barbadense, which its origin centered in South America, G. laceolatum, in Mexico, and G. hirsutum, with origin centered in Mexico and south of the United States. Out of commercial fiber production, the species G. hirsutum and G. barbadense, tetraploid coming from the New World, G. herbaceum and G. arboretum are diploid of the Old World (GRIDI-PAPP, 1965). Brazil is the center of origin for G. mustelinum and an important center of diversity for G. barbadense and G. hirsutum r. maria galante. It has no diploid varieties. According to FREIRE et al. (1990), G. mustelinum, a genuinely Brazilian feral species, was never improved or commercially explored, despite an evident introgression of G. hirsutum alleles in its genome (WENDEL et al. 1994). Its center of origin is the Brazilian Northeast, where some populations may still be found in the municipalities of Caiacó, RN and Caraíba, BA (FREIRE, 2000). In Brazil, the species G. barbadense is widely distributed, in its feral and sub-spontaneous forms, from the Amazon basin to the tropical forest, from Rio Grande do Norte to Espírito Santo, at the Pantanal rim, in the Central West cerrados (MT, MS, GO) and the lowlands of the semiarid Maranhão and Piauí. Two species are found, G. barbadense var. barbadense and “Ox-kidney” G. barbadense var brasiliense, present in indigenous villages and backyards. The barbadense variety was probably introduced from the Caribbean islands, while the brasiliense came from the Amazon forest. The segregation of the two varieties in Brazil is the result of agricultural activities (BOULANGER and PINHEIRO, 1972), where the populations were maintained and cultivated as “local” varieties. Currently, the “modern” varieties of G. barbadense are seldom cultivated in Brazil. Gossypium hirsutum is represented by two biotypes in Brazil. The race latifolium, also known as “upland” cotton, is the main cotton farmed in Brazil. The maria galante race, known as “Mocó” or “arboreal” cotton, was very common in the Northeast during the seventies, and is currently restricted to very few areas. The chains of special, conventional and transgenic cottons have lived together in a satisfactory way, without records of coexistence problems. The cotton planted area in Brazil during the 2007/2008 crop was about a million and one hundred hectares, of which over 85% is concentrated in the Cerrado biome, especially in the states of Mato Grosso, Bahia, Goiás and Mato Grosso do Sul. Other tillage area is present in other Brazilian states, mainly in the Semi-Arid of the Northeast, Paraná, Minas Gerais and São Paulo (IBGE, 2008). Cotton plants are noticeable for their aspects of usefulness, including weaving fibers and oleaginous and proteinaceous seeds used in human and animal food. The species were improved by man since antiquity, both in Old and New Worlds. Cotton (Gossypium spp.) is a plant domesticated by man since the year 3000 B.C., and is cultivated in all continents. Its main use is the production of fibers and food, especially for animals. The cotton plant (Gossypium hirsutum L.) is one of four species cultivated in the world for the production of cotton fiber (PENNA, J.C.V., 2005) and is economically exploited in a wide tropical band and some subtropical regions. Cotton in Brazil is among the ten main agricultural cultures and occupies the sixth place in cultivated surface over the world. The cotton plant is held as a plant very sensitive to interferences caused by plant pests, due to internal aspects (photosynthesis type C3, high photorespiration rate, etc.) and external, such as plant architecture and for displaying very slow initial growth, endowing the plant with a low competitive capacity against invading rivals. With the employment of recombinant DNA technology, the development of a genetically modified cotton lineage, Event GHB614 has the purpose of improving control and management of pest plants in cotton culture through selective use of a glyphosate-based herbicide. The effect of the herbicide is given by inhibiting enzyme EPSPS (aromatic amino acids production pathway), being the active ingredient duly registered in Brazil, including for the cotton culture. III. Description of the GMO and Proteins Expressed GlyTol® - Event GHB614 cotton – was genetically modified by inserting gene 2mepsps, responsible for expressing enzyme 5-enolpyruvylshikimate-3-phosphate synthase (2mEPSPS) with mutation of 2 amino acids. This modified enzyme grants cotton GlyTol® selectiveness to the herbicide effect of the active component glyphosate, enabling therefore the control of pest plants in post-emergence in crops without harming the cotton culture. Event GHB614 was obtained by inserting the gene of interest and elements regulating the genome of the Coker 312 cotton variety. The genetic modification of the Event took place through a system mediated by Agrobacterium tumefasciens containing vector pTEM2. Gene 2mepsps originates from corn (Zea mays) epsps gene changed through a site-directed mutation in just 2 (two) amino acids in the original peptide sequence, resulting in a protein featuring better binding affinity to glyphosate, keeping its functionality (shikimate and synthesis of aromatic amino acids pathway) even under conditions of spraying with the herbicide. The elements present between the left and right borders in vector pTEM2 include, besides gene 2mepsps, those elements regulating the gene expression. Therefore, chimeric gene 2mepsps contains: Ph4a748At promoters and intron 1-h3At; optimized transit peptide – TPotp C – directing the protein to plastids and the signal sequence of polyadenylation 3’ histonAt. Glyphosate [N-(phosphonomethyl)glycine)] is a systemic, post-emergent and non-selective herbicide widely used in agriculture. Glyphosate way of action consists in changing different biochemical processes vital to plants, such as amino acids, proteins and nucleic acids biosynthesis (GLASS, 1984). The herbicide is absorbed by the living tissue and translocated, via phloem, through the plant by roots and rhizomes, and its action inhibits specific enzymes, such as enolpyruvylshikimate-3-phosphate synthase (EPSPS) suspending the synthesis of aromatic amino acids (AMRHEIN et al., 1980; COUTINHO and MAZO, 2005). However, gene 2mepsps, originally isolated from cells suspended in corn (Zea mays) (LEBRUN, et al., 1997), includes substitution of 2 (two) amino acids from its original sequence, resulting in the expression of a protein insensitive to the glyphosate activity. The gene expressing the attribute of selectivity to glyphosate in Event GHB614 is called 2mepsps, originated from gene epsps in corn (Zea mays) with a change through site-directed mutation of just 2 (two) amino acids in its peptide sequence in position 102 (replacing threonine by isoleucine) and position 106 (replacing proline by serine) (LEBRUN et al., 1997), resulting in a protein featuring less binding affinity to glyphosate, keeping its functionality even under conditions of spraying with the herbicide. Protein EPSPS (5-enolpyruvylshikimate-3-phosphate synthase, E.C. 2.5.1.19) is a key enzyme in the shikimate pathway. Though the pathway is present in plants and several microorganisms, it is absolutely absent in mammals, fish, birds, reptiles and insects. These forms of life do not depend on the shikimate pathway, since they rely on their diet to obtain the aromatic products they need. Plants, on the other hand, must produce these essential amino acids to survive and multiply (GRUYS & SIKORSKY, 1999). Glyphosate acts on EPSPS inhibiting the synthesis pathway of the aromatic amino acids such as phenilalanine, tryptophan and tyrosine, which are precursors of other products, such as lignin, alkaloids, flavonoids and benzoic acids (STEINORÜCKEN & AMRHEIN, 1980; BUSSE et al., 2001; ZABLOTOWICZ & REDDY, 2004). GlyTol® cotton expresses enzyme 2mEPSPS that, because of lack of sensitivity to the action of the herbicide, makes maintaining the shikimate pathway possible, therefore enabling full development of the plant, even when sprinkled with such herbicide. IV. Aspects Related to Human and Animal Health The expressed polypeptide chain has molecular mass of 47 kDa and 445 amino acids, highly similar to the corn protein sequence (> 99.5%). Expression of the nuclear gene results in mRNA translated in the cytoplasm, with the polypeptide imported to the cytoplasts interior, where the enzyme plays its role. Glycosilation sites indwell in asparagines 118 and 394. For acute toxicity studies, high quantities of protein are necessary and the identity was directly proven, in SDS-PAGE and by immunologic detection through Western blot of the plant material and the bacteria-expressed material. Chromatographic analysis, mass spectroscopy and N-terminal sequence of the polypeptide displayed identical results. Quantification of protein 2mEPSPS in different tissues of Event GHB614 were conducted through immunoassays (ELISA). Detailed data are shown in items 2.5.3. Below, there is a summary of the findings: a. Amount of 2mEPSPS in cored seeds of GlyTol® cotton: results show that the protein was detected in all fractions related to GM seeds. Over 95% of 2mEPSPS was found in the grain (smooth seed) an also in cored seed. The linter fraction contains less than 0.5% of 2mEPSPS. The protein level of expression varied among different locations and glyphosate treatments. Values ranged from 16.2 µg/g to 30.5 µg/g of fresh matter in GlyTol® samples submitted to application of glyphosate and from 15.8 µg/g to 25.5 µg/g in samples not sprayed with the herbicide representing, on average, 0.0093% and 0.01% of total protein, respectively. b. Tenor of protein 2mEPSPS in different tissues along the crop cycle. Tenor of 2mEPSPS in young leaves decreased along the cycle, coming from 11.16 µg/g + 3.73 to 0.45 + 0.22 µg/g of fresh matter when reaching stage 4. In the stalk, the tenor of protein kept relatively stable between stages 2 and 4, while in roots, 2mEPSPS increased. In general, the contents of protein 2mEPSPS in GlyTol® cotton were higher in leaves during stage 2 (7.94 + 2.87 MF) and lower in pollen (0.16 + 0.0 µg/g). There is a commercial device available for specific immune detection of the EPSPS protein in event GHB614. The detection technique of transgene by means of quantitative PCR is also validated and shall be at the disposal of those interested in case this request for commercial release is granted. Data on centesimal nutritional and compositional assessments of GlyTol® cotton and its equivalent to the non-modified parental, variety Coker312 and to other conventional varieties of cotton are summarized on Table 13 (OBERDORFER, 2010). The following analyses were conducted for this purpose: centesimal composition, fibers, micronutrients (minerals and vitamin E), total antinutrients, gossypol, cyclopropenoids, phytic acid, total amino acids and fatty acids. Cored seeds were used for compositional analyses of GlyTol® cotton (kernel + linter), coming from plants cultivated in 17 places of the United States during the 2005 and 2006 crops. In addition to this material, compositional analyses were carried out in linter, husk, delinted seeds, cotton meal (raw and roasted) and cotton oil (raw, refined and deodorized). Conventional cotton plants Coker312 and GlyTol® received typical cultural treatments with addition of glyphosate in parcels of GlyTol®. Additionally, one parcel of the same cotton was conducted with no use of the glyphosate herbicide. Cultures were conducted in typical conditions to cotton, except for the application of glyphosate, carried out in three parcels containing GlyTol® cotton. For the sake of comparison, 3 parcels of GlyTol® cotton were maintained in the same conditions, without application of glyphosate. Data showed that for the majority of the components examined there was no significant difference identified between GlyTol® cotton and its isoline. In cases where the change did occur, it failed to represent nutritional impact for the following reasons: - values found for GHB614 and coker312 samples were within the range reported for commercial products, especially for cyclopropenoids (malvalic, sterculic and dihydrosterculic fatty acids); - there was no trend in the change found. In the fiber (neutral) analysis, for instance, in some tissues higher values were found in GHB614 and lower in others, compared to Coker312. - differences in nutrient levels were found in just one product. Values measured for myristic fatty acid (C14:0) showed difference between genotypes only when analyzed in refined oil, what was not the case for cored seeds, delinted seeds and raw oil; - differences in nutrient levels were so small that fail to carry any nutritional relevance (variation of 0.1% for fatty acids measured in husk and fibers between genotypes). The mineral contents analyzed in GHB614 and Coker 312 seed was equivalent between genotypes (Table 20), except for Iron and Calcium that, for delinted seeds (Table 21) the tenors were higher in GHB614. Even so, the recorded values are within the average band described by other authors. Variations found for other chemical compounds (nutrients and anti-nutritional factors) were recorded on Tables 21 to 28 and are within the isoline equivalent values. Composition of amino acids analyzed in different parts of GHB614 and Coker 312 are shown in Tables 29 to 32. Samples of cotton meal tested displayed increased values of amino acids, despite the origin of the tested material in the preparation, as against the values found in the literature. The results may be a consequence of the preparation way or a specific characteristics of the parental variety used in the transformation. Differences between tested samples, GHB614 and Coker 312 were not statistically significant, which makes true a statement that they are equivalent regarding amino acid composition. Cotton is seldom consumed by mammals, birds and other species of sylvan animals present in the cultivation area. Non-target organisms, such as predators and preys of cotton pests present in cotton tillage will be exposed to lower levels of the 2mEPSPS protein through trophic transfer. However, there is no evidence of negative effects of the protein over such populations. Same as with GlyTol® cotton, the GHB614 cotton showed to be equivalent to the conventional cotton plant, except for its characteristic of tolerance to glyphosate, its basic interaction with microorganisms present on the environment failed to show differences of conventional cotton interactions. An experiment was conducted with poult during growth. One hundred and forty birds in two subgroups (males and females) with seven repetitions (10 birds each) were tested with commercial cotton, the isoline Coker 312 and event GHB614. The experiment lasted 40 days, when the following parameters were analyzed: animal performance, alimentary conversion and general health characteristics of the bird. There was no alteration that could be attributed to the presence of genetically modified cotton. There was no significant difference regarding mortality or pathological changes in different organs. Protein degradability was tested in a system that simulated human gastric fluid. One in vitro assay was conducted following the methodology described by THOMAS et al. (2004), describing the protocol using pH 1.2, addition of pepsin (Sigma), incubation at 37 ºC for 0.5 to 60 minutes and use of positive and negative controls with proteins peroxidase and ovalbumin. Solutions containing the peptides resulting from the essays were submitted to SDS-PAGE analysis (LAEMMLI, 1970) and stained with Comassie blue (NEUHOFF et al., 1988). Figures 19 and 20 illustrate the gels SDS-PAGE where protein 2mEPSPS was rapidly and completely degraded in such essay conditions. The peroxidase control protein was rapidly digested, while ovalbumin, slowly, as expected (HERUET-GUICHENEY et al., 2009). The simulation is probably a simplified imitation of the condition prevailing in the digestive tube while multiple enzymes act simultaneously and sequentially, leading to complete degradation. The result is an additional guarantee that the intact protein is not absorbed and absence of systemic interference, and already indicates low allergenic potential of such protein. In a acute toxicity assay, when high concentrations of proteins 2mEPSPS and BSA (bovine serum albumin) were administered per os in animals and after 15 days of essay, the individuals were sacrificed and submitted to necropsy for macroscopic analysis. Animals were anesthetized by isoflurane inhaling before the necropsy and later submitted to examination of thoracic and abdominal cavity and their main organs and tissues. The results showed no correlation between abnormalities found for both treatments. The changes are common due to the animal race, age and test conditions, therefore held as spontaneous variations, keeping no relation with effects caused by the 2mEPSPS protein. Besides, the assessment of clinical signs, data on corporeal weight and weight gain of animals coming from the same essay failed to evidence statistically significant differences, indicating that oral administration of highly concentrated 2mEPSPS protein does not result in any evidence of risk to human/animal health due to its use in food (ROUQUIE, 2006). Later, another acute toxicology study was conducted with rodents, injecting up to 10 mg of purified protein directly in the animals’ blood flow. The methodology applied followed the guidelines prescribed by US-EPA Health Effects Test Guidelines OPPTS 870.1100 and OECD Test Guideline 425, using components aprotinin and melitin as negative and positive controls, respectively. Animals treated with 1 mg and 10 mg of 2mEPSPS did not display mortality or symptoms of toxicity even after 15 days from the treatment. At the end of the experiment, when the rodents were submitted to necropsy and macroscopic examination of organs and tissues, no alteration or abnormality was recorded, even in individuals submitted to intravenous 10 mg of 2mEPSPS (ROUQUIE, 2008). In assessing the allergenicity potential, source of genes, historic of exposure, protein digestibility and a comparison with sequences of known allergenic proteins were taken into account. Gene 2mepsps was obtained from sources that are recognized as non causing allergic reactions and the proteins have a long history of safe use, including in other GMOs or derivates already approved for marketing in Brazil. As demonstrated in the scientific literature, a contributing factor towards allergenicity of proteins is its high concentration in food. The majority of allergenic proteins is present in high concentration in specific foods, generally representing from 2% to 3% or even up to 80% of total proteins (ASTWOOD & FUCHS, 1996). Conversely, protein 2mEPSPS is found in extremely low levels in the tissues analyzed, about 100 ng per mg of seed, with percentages ranging from 0.5% to 0.00016% of the plant protein content, depending on plant stadium and part analyzed. Besides, molecules produced by gene 2mepsps are readily degraded when ingested. As it is known, cotton products (kernel oil and short fibers) used for human and animal consumption are highly processed and therefore 2mEPSPS is not detected in such materials. Even considering immediate degradation of protein 2mEPSPS after ingestion and non-detection of such proteins in GlyTol® cotton derived products, existence of possible sequences of amino acids displaying similarities with already described allergens was investigated. Data presented in HEROUET et al. (2009) paper, it remains clear that protein 2mEPSPS displays similarity only with other EPSPS enzymes of different species. Besides, it fails to show any similarity with compounds recognizedly allergenic or toxic, and has no similarity with epitopes and glycolization sites. A result of sequence similarity is held positive when an identity higher than 35% among sequences of amino acids is recorded, or when there is identity in a sequence of 6 (six) contiguous amino acids. This number of amino acids has been a subject of discussion, and a number of 8 (eight) amino acids has been proposed to avoid false positive results (ILSI, 2001). In silico searches were conducted to identify all allergens known to feature an amino acid identity higher than 30% with protein 2mEPSPS in a window of 80 amino acids. A complete sequence of protein 2mEPSPS was compared with AllergenOnline (version 8.0, 1313 sequences). AllegenOnline (http://allergenonline.com) is a list of resources targeted to known allergens and putatives. This allergen databank was specifically developed to predict allergenicity of new proteins by the Food Allergy Research and Resource Program (FAR-RP. The databank is updated yearly through NCBI and International Union of Immunological Societies (IUIS) searches, as well as through assessment at the entry of candidates for evidence of allergenicity. Additions and deletions on the databank are conducted by a revision panel of international experts in allergy to assess whether the proteins are allergens or putative allergens based on predefined criteria. Criteria e references for evidence of allergenicity in groups are supplied on the website. In March, 2009, another in silico search was conducted in an attempt to determine whether protein 2mEPSPS shares the identities of an amino acid with known toxins. The full protein 2mEPSPS amino acid sequence was then contrasted with all sequences of the protein (including potential toxins) present in six wide databanks of public reference data: Unioprot-Swissprot (version 56.7, 2009; 408.099 sequences), Uniprot-trEMBL (version 39.7, 2009; 7,001,017 sequences), PIR (Protein Identification Resources, version 80, 2004; 283,416 sequences), Nri-3D (2007, 56,020 sequences), DAD (DEBJ Amino acid sequence Database, version 44.0, 2008; 2,561,319 sequences), and Genepept (version 169, 2009; 6,185.784 sequences). For all searches, the comparison algorithm used was BLASTP (basic local alignment search tool program for protein-basic protein), maintained by the National Center for Biotechnology Information (NCBI, ALTSCHUL et al., 1997). The BLOSUM62 punctuation matrix enabled comparison of sequences with no less than 62% divergence (HENIKOFF and HENIKOFF, 1998). The search for putative sites for N-glycosylation of protein 2mEPSPS was also examined based on its consensus known sequence. The sequences were Asparagine-Xaa-Serine/Treonin (where Xaa represents any amino acid, except Proline) and Asparagine-Xaa-Cysteine. The algorithm used to conduct analyses was the FindPatterns of the integrated software CGC. The final result of similarity BLAST, conducted in 2009, failed to show evidence of similarity between protein 2mEPSPS and any known allergen protein. The epitope similarity FindPatterns Analysis confirmed that there was no evidence of similarity with allergens, therefore featuring no identity with eight contiguous amino acids with known allergens, using the AllergenOnline databank. Results also showed lack of similarity withy known toxins, or any functional homology between the 2mEPSPS and known toxins. As expected, the BLAST results showed that protein 2mEPSPS displays high structural similarity only with other EPSPS proteins, including corn protein (>99%). The high similarity of 2mEPSPS proteins and the sylvan EPSPS indicates a safety profile. Finally, putative locals of N-glycosylation present in the sequence of 2mEPSPS, in positions 118 and 394, were identical to the locals of the EPSPS protein in corn, enabling a conclusion that the two putative locals fail do display safety problems (HEROUET et al., 2009). Summarizing, date submitted by Applicant support the conclusion that protein 2mEPSPS, under the conditions prevailing in derivatives of GlyTol® cotton fails to pose allergenicity risks to humans and animals higher than the threats posed by non-transgenic varieties. V. Environmental Aspects According to data surveyed by ABRAPA – Associação Brasileira de Produtores de Algodão (Brazilian Cotton Producers Association), Brazil cultivated 1.07 million hectares on the 2008/2009 crop, of which 300 thousand hectares were sowed with genetically modified cotton (SILVEIRA et al., 2009). The expectations of ABRAPA for the 2009/2010 crop is a reduction of about 23%, to 850 thousand hectares, with a production of 1.2 million of tons of cotton lint. Experimental results in Brazil generated by essays authorized by CTNBio and MAPA showed a significant reduction in the use of herbicides in tillage, which simplifies the system of pest plant control when compared with conventional cotton. An example of the high dissemination of the product are the adhesion rate to the technology attained in the United States and Australia: In 2006, nine years after the first commercial plantation of glyphosate tolerant cotton (Event MON1445), American farms showed that 65% of the planted area in the country was already using such Event. In Australia, the first commercial area was sowed in 2000 and, in just six years, the area so planted represented 75% of the cotton planted area in that country. These countries that feature, therefore, a long history of use in the environment, there is no record of adverse effects of environment degradation as an effect of the technology that enables the management of pest plants with glyphosate. In another study, CHIAVEGATO (2009b) assessed the Event response to different doses of the herbicide in different growth phases, making possible to evaluate whether the level of expression of gene 2mepsps was sufficient to protect the plant, as well as to assess the specificity of the gene to grant selectivity just to the glyphosate herbicide. In Annex II of the process, there is a complete description of the protocols and treatments used in the essays conducted in Brazil. The results obtained by analyzing phenologic data indicated that plants derived from Event GHB614 showed tolerant go glyphosate, including high doses of the herbicide, since the parameters assessed failed to statistically differ from data analyzed in plants managed without the herbicide. This indicates that protein 2mEPSPS was expressed in a level sufficient to grant due protection to the plant enabling maintenance of its growth and normal development. When the plants were submitted to the herbicide ammonium gluphosinate with the purpose of assessing specificity of the Event to selectivity of just the active ingredient glyphosate, both GM (GlyTol®) and nGM cotton varieties showed to be highly sensitive, leading to total injury of plants 14 days after application, showing that gene 2mepsps acts solely in glyphosate tolerance, with no additional survival or adaptive advantage attribute regarding GlyTol® cotton. The test demonstrated, besides that, should the need for eradication of Event GlyTol® derivative plants be the case, the use of other non-selective herbicides to the culture keeps being efficient for this purpose. According to FREIRE (2000), the likelihood of gene flow between GM and feral cottons is remote given the isolation of spatial distribution foreseen for commercial cultivars (distributed in high-technology tillage areas in the cerrado) in locations knowingly exempt from sylvan types. In case the transfer does take place, the adaptive advantage represented by a tolerance to a specific herbicide shall be null, since the cotton plants are cultivated in small areas and manually weeded. Besides, no biochemical/physiological change affecting the ability of natural survival of plants in the environment was detected. The new attribute that enables selective use of a wide ranged herbicide in post-emergence fails to insert any competitive or adaptive advantage to the individual, even in stress situations, such as pathogen infestations or competition with pest plants. The differentiated phenotype of plants expressing gene 2mepsps is only perceived under invading plants management conditions where the glyphosate herbicide has been used. Finally, under Brazilian conditions, the cotton cultivation regions fail to display any pest plat that may be sexually compatible with the cultivated species of Gossypium. Apparently, the possibilities of crossing between cotton and other cultivated Malvaceous species, (such as okra, Hibiscus sculentus, or Hibiscus cannabinus and the vinegar plant (Hibiscus sabdariffa) are quite remote. A significant change is not expected in organisms present in the farm ecosystem where cultivation of GlyTol® cotton is foreseen, since this GMO is only differentiated from the conventional parental for the presence of gene 2mepsps, which acts in the selectivity to glyphosate and fails to display any pleiotropic or epistatic effect. Protein 2mEPSPS expressed in Event GHB614 originates from the EPSPS of corn, containing two changes in its amino acid sequence: substitution of one threonine for a isoleucine in position 103, and proline for a serine in position 107. Even so, protein 2mEPSPS has 99.5% of homology with the corn EPSPS , 86% with rice, 79% with grape, 77% with rice and 75% with tomato (HEROUET-GUICHENEY et al., 2009). Up to now, no bibliographic reference suggests any adverse effects in simbionts, predators, pollinators, parasites or competitors caused by the EPSPS protein. Organisms interacting with cotton culture, such as pests, rodents and birds, may sustain some damage due to presence of the gossypol compound (BELL, 1986; ABOU-DONIA, 1989) that occurs in similar levels both in GlyTol® and its conventional parental, therefore keeping no relation with the genetic modification on screen. In Brazil, one of the treatments applied to GlyTol® cotton and its conventional isoline, cultivated in the environment, was biotic stress, where no pests and diseases were controlled along the cultivation cycle. Data collected and presented by CHIAVEGATO (2009a) show that pests, such as cotton worm, Spodoptera, cotton bollworm, aphis and whitefly, and phytopathogens ramularia, ramulose, and blue disease (virosis) infested both GlyTol® and the non modified lineage. This is an indication that no species of pest or phytopathogen displayed differential preference for any of the genotypes or had favored increase of its population. CURRIER (2006) made a study comparing morphology, viability and survival rate of cotton pollen of GlyTol® (genetically modified) and Coker 312 (conventional) genotypes. To this end, 14 plants derived from Event GHB614 and 10 coming from the conventional parental were cultivated in vases inside a vegetation house in the Bayer Cropscience premises (Research Triangle Park, Raleigh, NC, USA). Pollen samples were collected by hand and transferred to specific environments in order to conduct the study. Viability was measured by a method described by BARROW (1981), which analyzes the growth of initial structures of the pollinic tube in the microscope. This analysis was repeated for three days. Results showed that initial viability of GHB614 and Coker 312 cotton pollens exceeded 90%. Decrease of viability revealed a kinetics along of a similar term for the genotypes, without statistical differences. Based on the data and the bibliographic references, it is not likely that GlyTol® cotton has greater reproduction and survival ability in any environment that is in any way different from already marketed cultivars. Adaptive advantage of Event GHB614 is recorded only when the culture is sprayed with the glyphosate herbicide, where plants containing 2mepsps maintain their normal development, with no injuries or phytotoxicity. The use of GlyTol® cotton, event GHB614 has the purpose of improving the management of pest plants in the tillage of corn in post-emergence, using a herbicide that features wide spectrum of action. This characteristics of the Event does not result in tolerance to any environmental biotic element and therefore there is no organism that is a target of the technology. Invading plants normally occurring in cotton production areas that have caused significant damage and/or have reduced the intrinsic quality of the product harvested are: Bidens pilosa (Spanish needle), Cenchrus Echinatus (grass-bun), Ipomoea ssp. (morning glory) and perennial Malvaceae (Sida ssp.). Weed infestation in cotton culture results also in increased damages caused by pests and diseases that are hosts of such weeds; increase dispersion of invaders’ seeds; multiply the need for cultivation and chemical control practices and reduce soil structure and humidity due to the increased soil preparation (harrowing) in pre-sowing to reduce initial infestation. Use of minimum cultivation or direct sowing have been important measures to soil conservation in areas featuring greater risk of erosion. This way, control of pest plants through the use of glyphosate in post-emergence shall probably be an important component for systems aimed at better soil conservation, because of the reduced movement in pre-sowing and increased soil structure due to maintenance of roots and plant residues (FAWCETT & TOWERY, 2004; SANKULA, 2006). In field studies conducted abroad, Applicant’s technicians have frequently visited experimental areas to collect culture management data, and recorded infestation by pests, diseases and presence of natural enemies. In no case variations regarding increase or reduction of pests, diseases, pollinating insects, predators and any other beneficial organism were recorded in the experiments, when contrasted to the cultivation of conventional corn (Van DUYN, 2007). Results of an environmental study conducted by CHIAVEGATO (2009a) revealed that no pest species or phytopathogen had any differential preference for one of the genotypes (VGM or NM) nor has favored the population increase. One of the risk hypothesis attached to commercial release of a genetically modified culture, there is one according to which these VGM may turn into weed, with greater ability of surviving and invading natural habitats and, consequently, endanger their biodiversity. Therefore, it is important to assess whether the GM genotypes exhibit differentiated phenotypic characteristics that may make them more invasive (WILLIAMSON, 1993). Some important attributes of pest plants, such as dormancy, phenotypic plasticity, indeterminate growth, continuous flowering and ease seed dispersion (BAKER, ‘974) nave been eliminated from the majority of agriculture cultures along generations during genetic improvement. These characters are not pursued for gene transfer in cultivars, either by biotechnology (recombinant DNA) or by classical improvement, since such attributes drastically reduce the agronomic performance of modern varieties. Besides, these characteristics generally are commanded by different genes. CRAWLEY et al., (2001) discuss the results obtained in a long term study assessing the performance of GM cultures in natural habitats. Four cultures (canola, potato, corn and beet) showing the additional attributes of tolerance to herbicide or resistance to insects, were cultivated in 12 different habitats and monitored for 10 years. There was no record of in which the genetically modified plants were more invasive or more persistent than their conventional parental ones. One did not expect these additional characteristics of Events could increase the development of plants in such habitats. On the other hand, these results cannot discard the hypothesis that other genetic modifications could change the invading ability of a VGM, but also failed to indicated that such plants could survive for long periods of time outside culture cultivation conditions. LEMEAUX, (2009), in an extensive revision where he analyzed scientific publications related to risk analysis of genetically modified products, concluded that though no human activity could guaranty 100% safety, genetically modified cultivars and their products currently available in the market are as safe as those resulting from conventional methods. VI. Restrictions to the Use of the GMO and GMO Derivatives Technical Opinions related to agronomic performance concluded that there is equivalence between transgenic and conventional plants. Therefore, information indicates that transgenic plants are not fundamentally different from non-transformed cotton genotypes, except for the tolerance to the glyphosate herbicide. Besides, there is no evidence of adverse reactions to the use of GlyTol® cotton event GHB614. For these reasons, there are no restrictions to the use of such cotton or its derivatives in both human and animal food. According to Article 1 of Law no. 11,460, of March 21, 2007, “research and cultivation of genetically modified organisms are forbidden in indigenous and conservation unit areas”. VII. Considerations on Particulars from Different Regions of the Country (Subsidies to Monitoring Bodies) There are not Creole varieties of cotton and chains of special, conventional and transgenic cottons have lived side-by-side in a satisfactory way, with no record of coexistence problems. Zones where cultivating GM cotton, either of this event or other transformation, is restricted shall be strictly monitored by supervising bodies, both in the trade of seeds in such areas and in technical guidance and monitoring of the applying legal entity. Such areas are located in the south of Rio Grande do Norte and the Northeast of Bahia, all of the Amazon region, Pantanal, southeast of Piaui, west of Pernambuco and Atlantic Forest, encompassing the states of RN, PB, AL, SE, BA, MG and ES. VIII. Conclusion Whereas 1. Cotton event GHB614 is as safe for human and animal consumption as its conventional equivalent. 2. Protein 2mEPSPS has no homology with toxic or allergenic substance and has no glycosilation sites additional to those already existent in corn EPSPS. 3. Protein 2mEPSPS is rapidly degraded in the presence of digestive tract enzymes. 4. No adverse effect was recorded in acute toxicology studies and animal food containing protein 2mEPSPS. 5. Plants derived from Event GHB614 have the same survival and adaptation ability regarding the environment than conventional cotton. 6. Agronomic characteristics of GlyTol® cotton are only differentiated by selectivity to glyphosate, when compared to conventional cotton varieties. 7. The use of cotton and derivatives produced from GlyTol® cotton (Event GHB614) imply the same safety to human and animal health and to the environment as commercial conventional lineages, and even as genetically modified varieties, already approved and marketed, displaying selectivity to glyphosate. 8. The use of kernels or byproducts derived from Event GHB614, following the same recommendations and safety criteria already used for commercial cotton varieties, fail to represent greater exposure to any risk situation. CTNBio does not hold this activity a potential cause of significant degradation to the environment or hazardous to human and animal health. Restrictions to the use of the GMO in analysis and its derivatives are not conditioned to the provisions of the Ministry of Agriculture and Supply Directive 21/05. Under the provisions of Article 14 of Law nº 11,105/05, CTNBio holds that the request is in line with the legislation in force that guaranty environment, agriculture, human and animal health biosafety, and concluded that Cotton GHB614 (GlyTol®) is substantially equivalent to conventional cotton and that its consumption is safe for human and animal health. Regarding the environment, CTNBio concluded that Cotton GHB614 (GlyTol®) is not a potential cause of significant degradation to the environment, keeping with the biota a relation identical to that of the conventional cotton. Regarding the post-commercial release monitoring plan, CTNBio determines that the following instructions shall be attended and conducted the monitoring techniques mentioned below. (a) Monitoring must be conducted in commercial cultures and not experimental ones. Areas selected for monitoring shall not be separated from the others, be fenced or display any condition that may be a non-commercial standard. (b) Monitoring must be conducted in a model comparative between conventional cultivation and GMO cultivation systems, where data collection shall be made by sampling. (c) Monitoring must be conducted in biomes that are representative of the main GMO culture areas and, whenever possible, include different type of producers. (d) Monitoring must be conducted for a period of at least five years. (e) For all monitoring procedures, the applicant shall detail the data on all activities conducted in pre-sowing and sowing, on its performance, reporting all activities carried out in the monitoring area during the culture cycle, in harvesting activities and climatic conditions. (f) Any hazard to human and animal health shall be monitored through official adverse effects notification systems, such as SINEPS – Sistema de Notificação de Eventos Aversos Relacionados a Produtos de Saúde the Adverse Effects Related to Health Products Notification System as regulated by ANVISA. (g) Analytical methods, results attained and their interpretation must be developed in line with independence and transparence principles, except for commercial secrecy aspects previously justified and defined as such. (h) On technical and scientific grounds, CTNBio reserves the right to review this Opinion at any time. Technical Monitoring Actions to be Conducted (a) Nutritional state and sanity of GMO plants. (b) Chemical and physical soil attributes related to fertility and other basic pedologic characteristics. (c) Soil microbial diversity. (d) Soil dispersion bank. (e) Community of invading plants. (f) Development of resistance to herbicide in invading plants. (g) Residues of herbicide in the soil, kernels and aerial part. (h) Gene flow IX. Bibliographic References ABOU-DONIA, M. B. 1989. Gossypol. In: P. R. Cheeke (ed.) Toxicants of Plant Origin. vol. 4:Phenolics. pp 1–22. CRC Press, Boca Raton, FL. 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Genetically Engineered plants and foods: a scientist´s analysis of the issues (part II). Annu. Rev. Plant Biol. V.60, p.511-559, 2009. LI, M. et al. Evaluation of cottonseed meal derived from genetically modified cotton as feed ingredients for channel catfish, Ictalurus punctatus. Aquacult. Nutr., v. 14, n. 6, 2008. MUNRO, J.M. 1987. Cotton. 2nd Ed. John Wiley & Sons, New York, NY. NEUHOFF, V., AROLD, N., TAUBE, D., EHRHARDT, W., 1988. Improved staining of proteins in polyacrylamide gels including isoelectric focusing gels with clear background at nanogram sensitivity using Coomassie Brilliant Blue G-250 and R-250. Electrophoresis 9, 255–262. OBERDORFER, R. Nutritional Impact Assessment reporto n glyphosate tolerant cotton transformation Event GHB614. Bayer Cropscience. Internal Report, 97p. 2010. M-289161-04-1. OECD. 2002. Task Force for the Safety of Novel Foods and Feeds. Draft Consideration for the Safety Assessment of Animal Feedstuffs Derived from Genetically Modified Plants. ENV/JM/FOOD(2001)8/REV1. France. PENNA, J.C.V. Melhoramento de algodão. Inc: Melhoramento de espécies cultivadas. Borém, A (Ed.) Viçosa; Ed. UFV.p. 15-53.2005.969p. ROUQIE, D. 2mEPSPS protein. Acute toxicity by intravenous injection in mice. Internal report, Bayer CropScience, 51p. 2008. ROUQUIE, D. 2mEPSPS protein. Acute toxicity by oral gavage in mice. Internal Report. Bayer CropScience, 64p. 2006. SANKULA S. 2006. Quantification of the impacts on US agriculture of biotechnology-derived crops planted in 2005. National Center for Food and Agricultural Policy. Washington, DC 20036. 110 pages. www.ncfap.org. # M-291016-01-1. SILVEIRA, D. et al. Fibras são saudáveis. In: Anuário brasileiro do algodão 2009. Ed. Gazeta Santa Cruz, 2009, 128p. STEINRÜCKEN H.C., AMRHEIN N. 1980. The herbicide glyphosate is a potent inhibitor of 5- enolpyruvylshikimic acid-3-phosphate synthase. Biochemical and Biophysical Research Communications. 94(4): 1207-1212. THOMAS, K., AALBERS, M., BANNON, G.A., BARTELS, M., DEARMAN, R.J., ESDAILE, D.J., FU, T.J., GLATT, C.M., HADFIELD, N., HATZOS, C., HEFLE, S.L., HEYLINGS, J.R., GOODMAN, R.E., HENRY, B., HEROUET, C., HOLSAPPLE, M., LADICS, G.S., LANDRY, T.D., MACINTOSH, S.C., RICE, E.A., PRIVALLE, L.S., STEINER, H.Y., TESHIMA, R., THOMAS, K., VAN REE, R., WOOLHISER, M., ZAWODNY, J., 2004. A multi-laboratory evaluation of a common in vitro pepsin digestion assay protocol used in assessing the safety of novel proteins. Regul. Toxicol. Pharmacol. 39, 87–98. USDA - U.S. Department of Agriculture, Animal and Plant Health Inspection Service. Petition for Determination of Non-regulated Status for Glyphosate-Tolerant cotton: GlyTol™ cotton Event GHB614. USDA - U.S. Department of Agriculture, Animal and Plant Health Inspection Service Federal Register Notification: Bayer CropScience; Determination of Non-regulated Status for Cotton Genetically Engineered for Glyphosate Herbicide Tolerance. U.S. E.P.A. (United States Environmental Protection Agency), 1998. Prevention, Pesticides and Toxic Substances (7101), Health Effects Test Guidelines OPPTS 870.1100, Acute Oral Toxicology, EPA 712-C-98-190, December 2002, 35 pages. Van DUYN, G. USDA Field termination reports for glyphosate tolerant cotton, 32p. 2007. WENDEL, J.F.; ROWLEY, R.; STEWART, J.M. Genetic diverstiy in and phylogenetic relationships of the Brazilian endemic cotton, Gossypium mustelinum (malvaceae). Plant Systematics and Evolution, v.192, p,49-59, 1994. WILLIAMSON, M. Invaders, weeds and the risks from GMOs. Experientia, 49, 219–224. 1993 ZABLOTOWICZ, R. M.; REDDY, K. N. Impact of glyphosate on the Bradyrhizobium japonicum symbiosis with glyphosate-resistant transgenic soybean: a minireview. J.Environ. Qual., v.33, n. 3, p.825-831, 2004. ZABLOTOWICZ, R. M.; REDDY, K. N. Impact of glyphosate on the Bradyrhizobium japonicum symbiosis with glyphosate-resistant transgenic soybean: a minireview. J.Environ. Qual., v.33, n.3, p.825-831, 2004. ZHANG, J. et al. Transgene integration and organization in Cotton (Gossypium hirsutum L.) genome. Transgenic Research, v. 17, n. 2, p. 293-306, 2008.
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
molecular traditional methods
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment: National Biosafety Commission
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Authorization expiration date (a blank field means there is no expiration date) Not Applicable
E-mail:
Organization/agency name (Full name):
National Biosafety Technical Commission
Contact person name:
Paulo Augusto Viana Barroso
Website:
Physical full address:
SPO Area 5 Qd 3 Bl B S 10.1 Brasilia DF
Phone number:
556120335087
Fax number:
Country introduction:

Brazil had the first biosafety law approved in 1995. After the identification of the need to improve the biosafety system of Brazilian genetically modified organisms, a new law was published. The Law 11.105 / 05 establishes a technical committee dedicated to the analysis of the safety aspects of genetically modified organisms and a council of ministers that is dedicated to the analysis of the socioeconomic aspects of the commercial release of genetically modified organisms. In this context, Brazil already has several commercial products that involve genetically modified organisms (plants, human and veterinary vaccines, microorganisms for fuel production) and products derived from new genetic modification techniques.

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Stacked events:

At the discretion of, and upon consultation with, CTNBio, a new analysis and issuance of technical opinion may be released on GMOs containing more than one event, combined through classic genetic improvement and which have been previously approved for commercial release by CTNBio

Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Dr. Paulo Augusto Viana Barroso (President of national Biosafety Commission)

Canada
Name of product applicant: Bayer CropScience
Summary of application:

Bayer CropScience has developed a cotton event tolerance to glyphosate-containing herbicides. This event was developed through Agrobacterium-mediated transformation of Gossypium hirsutum variety Coker 312 to express a modified 5-enolpyruvylshikimate-3-phosphate synthase (2mEPSPS) which is tolerant to inhibition by glyphosate-containing herbicides.

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Date of authorization: 13/03/2008
Scope of authorization: Food and feed
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.): BioTrack Product Database
Summary of the safety assessment (food safety):
Please see decision document weblinks
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment: Novel Foods Decision Document
Novel Feeds Decision Document
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Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
Health Canada
Contact person name:
Neil Strand
Website:
Physical full address:
251 Sir Frederick Banting Driveway, Tunney's Pasture, PL 2204A1
Phone number:
613-946-1317
Fax number:
Country introduction:

Federal responsibility for the regulations dealing with foods sold in Canada, including novel foods, is shared by Health Canada and the Canadian Food Inspection Agency (CFIA). Health Canada is responsible for establishing standards and policies governing the safety and nutritional quality of foods and developing labelling policies related to health and nutrition. The CFIA develops standards related to the packaging, labelling and advertising of foods, and handles all inspection and enforcement duties. The CFIA also has responsibility for the regulation of seeds, veterinary biologics, fertilizers and livestock feeds. More specifically, CFIA is responsible for the regulations and guidelines dealing with cultivating plants with novel traits and dealing with livestock feeds and for conducting the respective safety assessments, whereas Health Canada is responsible for the regulations and guidelines pertaining to novel foods and for conducting safety assessments of novel foods.

The mechanism by which Health Canada controls the sale of novel foods in Canada is the mandatory pre-market notification requirement as set out in Division 28 of Part B of the Food and Drug Regulations.

Manufacturers or importers are required under these regulations to submit information to Health Canada regarding the product in question so that a determination can be made with respect to the product's safety prior to sale. The safety criteria for the assessment of novel foods outlined in the current guidance document (i.e. Canadian Guidelines for the Safety Assessment of Novel Foods) were derived from internationally established scientific principles and guidelines developed through the work of the Organization for Economic Cooperation and Development (OECD), Food and Agriculture Organisation (FAO), World Health Organisation (WHO) and the Codex Alimentarius Commission. These guidelines provide for both the rigour and the flexibility required to determine the need for notification and to conduct the safety assessment of the broad range of food products being developed. This flexibility is needed to allow novel foods and food products to be assessed on a case-by-case basis and to take into consideration future scientific advances.

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Stacked events:

Food: Consistent with the definition of "novel food" in Division 28 of the Food and Drug Regulations, the progeny derived from the conventional breeding of approved genetically modified plants (one or both parents are genetically modified) would not be classified as a novel food unless some form of novelty was introduced into such progeny as a result of the cross, hence triggering the requirement for pre-market notification under Division 28. For example, notification may be required for modifications observed in the progeny that result in a change of existing characteristics of the plant that places those characteristics outside of the accepted range, or, that introduce new characteristics not previously observed in that plant (e.g. a major change has occurred in the expression levels of traits when stacked). In addition, the use of a wild species (interspecific cross) not having a history of safe use in the food supply in the development of a new plant line may also require notification to Health Canada. However, molecular stacks are considered new events and are considered to be notifiable as per Division 28.

Feed:

Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Neil Strand, Section Head of Novel Foods

Colombia
Name of product applicant: Bayern Crop Science
Summary of application:

Authorization of the genetically modified cotton GHB6143 tolerant to herbicide glyphosate 

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Date of authorization: 22/02/2016
Scope of authorization: Food
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.):
Summary of the safety assessment (food safety):
Based on the risk assessment, it can be concluded that the event shows the same risks as its conventional counterpart. Therefore the National Technical Biosafety Committee for GMO use exclusively in Health and human consumption (CTNSalud) recommends its authorization.
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment:
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Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
Ministerio de salud y proteccion social
Contact person name:
Daniel Rubio
Website:
Physical full address:
Carrera 13 No. 32- 76 piso 12, Bogotá
Phone number:
330 5000 ext 1256
Fax number:
Country introduction:

The 4525 decree of 2005, established the Ministry of Health and Social Protection as the competent authority for GMO for health and food purposes and creates the National Biosafety Technical Committee for GMO's used in health and food purposes (CTNSalud).

The CTNSalud is composed by the Ministry of Health and Social Protection, the National Food and Drug Surveillance Institute (INVIMA) and the Technology and Innovation Administrative Department (COLCIENCIAS). This committee is responsible for the assesment of risk assessments; to inquire for any additional information; assessment of any measurements in accordance to the Cartagena Protocol; and the recommendation for the authorization of GMO for health or food purposes.

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Relevant documents
Stacked events:
Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:
Colombia
Name of product applicant: BASF Química Colombiana S.A
Summary of application:

GMO authorization for GHB614 cotton as food for direct use or processing.

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Date of authorization: 11/06/2021
Scope of authorization: Food
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.):
Summary of the safety assessment (food safety):
Based on the risk assessment, it can be concluded that the event shows the same risks as its conventional counterpart. Therefore, the National Technical Committee for GMO use exclusively in health and human consumption (CTNSalud) recommends its authorization.
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Based on the risk assessment, it can be concluded that the event shows the same risks as its conventional counterpart. Therefore, the National Technical Committee for GMO use exclusively in health and human consumption (CTNSalud) recommends its authorization.
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment:
Upload:
Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
Ministerio de salud y proteccion social
Contact person name:
Daniel Rubio
Website:
Physical full address:
Carrera 13 No. 32- 76 piso 12, Bogotá
Phone number:
330 5000 ext 1256
Fax number:
Country introduction:

The 4525 decree of 2005, established the Ministry of Health and Social Protection as the competent authority for GMO for health and food purposes and creates the National Biosafety Technical Committee for GMO's used in health and food purposes (CTNSalud).

The CTNSalud is composed by the Ministry of Health and Social Protection, the National Food and Drug Surveillance Institute (INVIMA) and the Technology and Innovation Administrative Department (COLCIENCIAS). This committee is responsible for the assesment of risk assessments; to inquire for any additional information; assessment of any measurements in accordance to the Cartagena Protocol; and the recommendation for the authorization of GMO for health or food purposes.

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Relevant documents
Stacked events:
Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:
Japan
Name of product applicant: Bayer Crop Science Ltd.
Summary of application:

Cotton line GHB614 has been genetically modified to be tolerant to glyphosate herbicide (2mepsps, Gossypium hirsutum L.).

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Date of authorization: 21/01/2010
Scope of authorization: Food and feed
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.): OECD BioTrack Product Database
Summary of the safety assessment (food safety):
Please see the links below (in Japanese).
Upload:
Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment: Food safety assessment performed by Food Safety Commission of Japan (in Japanese), Food
Food safety assessment performed by Food Safety Commission of Japan (in Japanese), Feed
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Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
Food Safety Commission Secretariat,Cabinet Office,
Contact person name:
Kojiro Yokonuma
Website:
Physical full address:
Akasaka 5-2-20 Minato Ward,Tokyo,Japan
Phone number:
81 3 6234 1122
Fax number:
81 3 3584 7392
Country introduction:
Safety assessments of GM foods are mandatory under the Food Sanitation Law in Japan. The Ministry of Health, Labour, and Welfare (MHLW) legally imposes safety assessments of GM foods so that those that have not undergone safety assessments would not be distributed in the country. MHLW receives application and requests the Food Safety COmmission of Japan (FSCJ) to evaluate the safety of GM foods in terms of human health. Safety assessments are carried out by FSCJ.
Useful links
Relevant documents
Stacked events:

With regard to stacked events, FSCJ conducts the safety assessment of GM food based on the “Policies Regarding the Safety Assessment of Stacked Varieties of Genetically Modified Plants”.

Even if single events that are stacked have already approved, some products will be considered as new products and some will not.

Please refer to Article 5 and 6 of the MHLW’s notice, which is available at the following URL, for the details.

http://www.mhlw.go.jp/file/06-Seisakujouhou-11130500-Shokuhinanzenbu/0000053519.pdf

Article 6 was modified in 2014, and the modified version is available at the following URL.

http://www.mhlw.go.jp/file/06-Seisakujouhou-11130500-Shokuhinanzenbu/0000049695.pdf

Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Food Safety Commission of Japan (http://www.fsc.go.jp/english/index.html), Ministry of Health, Labour and Welfare (http://www.mhlw.go.jp/english/policy/health-medical/food/index.html)

Malaysia
Name of product applicant: BASF (Malaysia) Sdn. Bhd.
Summary of application:

Please refer to the decision document of the National Biosafety Board.

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Date of authorization: 17/01/2017
Scope of authorization: Food and feed
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.): Department of Biosafety Malaysia
CBD Biosafety Clearing House
Summary of the safety assessment (food safety):
Please refer to the Risk Assessment Report.
Upload:
Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment:
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Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
Department of Biosafety Malaysia
Contact person name:
Dr. Anita Anthonysamy
Website:
Physical full address:
Department of Biosafety, Ministry of Natural Resources, Environment and Climate Change Level 4, Block F11, Complex F Lebuh Perdana Timur, Precinct 1 62000 Putrajaya, Malaysia
Phone number:
+60380917322
Fax number:
+60380917371
Country introduction:

GM food safety assessment is a requirement by law under the Biosafety Act 2007 in Malaysia. The National Biosafety Board reviews and makes decisions on events based on a scientific/technical risk assessment, policy considerations as well as public input. The decisions and its related documents made are publicly available through the Malaysian Department of Biosafety Website and the Convention of Biological Diversity Biosafety Clearing House.

Useful links
Relevant documents
Stacked events:
Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Department of Biosafety, Ministry of Natural Resources, Environment and Climate Change Level 4, Block F11, Complex F Lebuh Perdana Timur, Precinct 1 62000 Putrajaya, Malaysia. Email: [email protected]. Url: www. biosafety.gov.my

Food Safety and Quality Division, Ministry of Health, Level 4, Menara Prisma, No. 26, Persiaran Perdana, Putrajaya, Malaysia, 62675. Phone: +603 88850797 Fax: +603 88850790 Email: [email protected]
Mexico
Name of product applicant: Bayer de México, S.A. de C.V.
Summary of application:

Authorization by COFEPRIS: 61


The genetically modified BCS-GHØØ2-5 cotton, as described in the application, expresses the 2mEPSPS protein which confers tolerance to glyphosate herbicides.

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Date of authorization: 22/12/2008
Scope of authorization: Food
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.):
Summary of the safety assessment (food safety):
UI OECD: BCS-GHØØ2-5 During the risk assessment of this GMO based on existing knowledge to date, no toxic or allergic effects neither substantial nutritional changes are observed. The event is as safe as its conventional counterpart. For more detail please find attached the risk assessment summary in this page.
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment:
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Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
CIBIOGEM
Contact person name:
Dra. Consuelo López López
Website:
Physical full address:
San Borja #938, Col. Del Valle • Del. Benito Juárez C.P. 03100, México, D.F.
Phone number:
+52 (55) 53227700
Fax number:
Country introduction:

México ha buscado garantizar la inocuidad de los productos biotecnológicos para el uso y consumo de su población.

Desde 1984 el artículo 282 bis 1 de la Ley General de Salud, contempló que la Secretaría de Salud debería regular aquellos productos biotecnológicos, o sus derivados, destinados al uso o consumo humano.

En un inicio, con fundamento en este artículo, la Secretaria de Salud evaluó la inocuidad alimentaria de productos biotecnológicos, para su comercialización con fines de uso o consumo humano. A partir de 2005, con la entrada en vigor de la Ley de Bioseguridad de Organismos Genéticamente Modificados (LBOGM), se realizó la adecuación de la regulación para dar lugar a la Autorización que es el acto administrativo mediante el cual la Secretaría de Salud, a través de la Comisión Federal para la Protección contra Riesgos Sanitarios (COFEPRIS), autoriza Organismos Genéticamente Modificados (OGMs), a efecto de que se pueda realizar su comercialización, así como su utilización con finalidades de Salud Pública o de Biorremediación.

Las facultades que corresponden a la Secretaría de Salud se estipulan en el artículo 16 de la LBOGM y lo relativo a la Autorizaciones se describe en los artículos 91 al 98 de dicha Ley.

Quienes pretendan obtener una Autorización para Comercialización e Importación de OGMs deben presentar ante COFEPRIS, una solicitud por escrito acompañada de la información a que se refiere los artículos 23 al 32 del Reglamento de la Ley de Bioseguridad de OGMs.

http://www.conacyt.gob.mx/cibiogem/images/cibiogem/normatividad/vigente/LBOGM.pdf

http://www.conacyt.gob.mx/cibiogem/images/cibiogem/normatividad/vigente/Reg_LBOGM.pdf

 

Courtesy translation

Mexico has sought to guarantee the safety of biotechnological products the use and consumption of its population. Since 1984, article 282 bis 1 from the General Law of Health, considered that the Secretary of Health should regulate those biotechnological products, or their derivatives, intended for food and feed use. Initially, the Secretary of Health evaluated the food safety of biotechnological products, based on this article, for commercialization with purposes of food, feed and processing. Subsequently in 2005, with the entry into force of the Law on Biosafety of Genetically Modified Organisms (LBOGM), the regulation was adapted to give rise to the Authorization, which is the administrative act through which the Secretary of Health, by means of the Federal Commission for the Protection Against Sanitary Risks (COFEPRIS), authorizes Genetically Modified Organisms (GMOs), to their commercialization, as well as their use for purposes of public health or bioremediation.

The faculties that correspond to the Secretary of Health are stipulated in Article 16 of the LBOGM and what is related to the Authorizations is described in Articles 91 to 98 of this Law. Those who seek to obtain an Authorization for GMOs merchandising and importation, must present to COFEPRIS, a written request accompanied by the information referred into articles 23 to 32 of the Regulation of the Law on Biosafety of Genetically Modified Organisms.

http://www.conacyt.gob.mx/cibiogem/images/cibiogem/normatividad/vigente/LBOGM.pdf

http://www.conacyt.gob.mx/cibiogem/images/cibiogem/normatividad/vigente/Reg_LBOGM.pdf

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Relevant documents
Stacked events:
Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Secretaría de Salud / Teléfono: +52 55 5080 5200 / Correo electrónico: [email protected]%20

New Zealand
Name of product applicant: Bayer CropScience Pty Ltd
Summary of application:

Glyphosate (N-phosphonomethylglycine) is a non-selective, broad spectrum herbicide. The mode of action of glyphosate is to specifically bind to, and block, the activity of a native plant enzyme, 5-enol-pyruvylshikimate-3-phosphate synthase (EPSPS). EPSPS is a key enzyme in the shikimate pathway in plants which links the metabolism of carbohydrates to the biosynthesis of ring-containing compounds including aromatic amino acids. Plant EPSPS enzymes are normally inactivated by glyphosate which leads to cellular deficiencies in certain amino acids resulting ultimately in the death of the plant.
In cotton line GHB614, tolerance to glyphosate is achieved through expression in the plant of a modified form of the EPSPS enzyme, 2mEPSPS, derived from corn. Two point (single nucleotide) mutations were introduced to the corn epsps gene to generate 2mepsps, using site directed mutagenesis. These changes significantly reduce the sensitivity of the 2mEPSPS enzyme to glyphosate, allowing it to continue to function in the presence of the herbicide.
Cotton line GHB614 has been developed for agriculture in major cotton producing countries worldwide.

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Date of authorization: 12/11/2009
Scope of authorization: Food
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.): OECD BioTrack Product Database
Summary of the safety assessment (food safety):
FSANZ has completed a comprehensive safety assessment of food derived from glyphosate tolerant cotton line GHB614, which included consideration of (i) the genetic modification introduced into the plant; (ii) the potential toxicity and allergenicity of the novel protein; and (iii) the composition of GHB614 cottonseed, compared with that from conventional cotton varieties. No public health and safety concerns were identified in the safety assessment. On the basis of the available evidence, including detailed studies provided by the Applicant, food derived from glyphosate-tolerant cotton line GHB614 is considered as safe and wholesome as food derived from other commercial cotton varieties.
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment: Application A614 - Food Derived From Glyphosate-Tolerant Cotton Line GHB614
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Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
Ministry for Primary Industries
Contact person name:
john vandenbeuken
Website:
Physical full address:
Pastoral House, 25 The Terrace, Wellington, 6012
Phone number:
0298942581
Fax number:
Country introduction:

New Zealand and Australia share a joint food regulation system for the composition of labelling of most foods. Food Standards Australia New Zealand (FSANZ) is the regulatory agency responsible for the development of the joint food standards in Australia and New Zealand. The main office (approximately 120 staff) is located in Canberra (in the Australian Capital Territory) and the smaller New Zealand office (approximately 15 staff) is located in Wellington on the North Island.

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Relevant documents
Stacked events:

FSANZ does not: Separately assess food from stacked event lines where food from the GM parents has already been approved; Mandate notification of stacked events by developers; Notify the public of stacked event ‘approvals’; List food derived from stacked event lines in the Code, unless the stacked event line has been separately assessed as a single line e.g. Application A518: MXB-13 cotton (DAS-21023-5 x DAS-24236-5)

Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Food Standards Australia New Zealand (FSANZ) (http://www.foodstandards.gov.au)

Philippines
Name of product applicant: BASF Philippines
Summary of application:

GHB614 is a cotton line developed by Bayer CropScience using Agrobacterium-mediated transformation vector pTEM2 containing a 2mepsps gene producing the 2mEPSPS protein, which confers tolerance to herbicide glyphosate.


 


In the years 2005 and 2006, compositional and nutritional analyses were performed using the raw agricultural commodity whole, linted cottonseed (fuzzy seed) grown at 17 field trial sites in the USA. The statistical evaluation of the composition data of GHB614 fuzzy seeds compared to their nontransgenic counterpart, Coker 312, showed that for most components no significant differences for the majority of the by-site comparisons were determined.


 


In compliance with Section 22(B) Article VII (Direct Use of Regulated Articles for Food and Feed, Or for Processing) of the JDC 01-2016, Bayer CropScience has published a copy of the approved PIS for Direct Use as FFP in Manila Bulletin and Manila Standard in its issue last March 14, 2017.


 


The assessment for the safety of the novel proteins for Direct Use as FFP, under the JDC 01-2016 follows the Codex Safety Assessment of Foods Derived from Recombinant DNA, and thus included: description of the host organism, transgenic plant, donor organisms, transformation system, inserted DNA, genetic stability, and expressed material. Safety assessment of expressed substances also included assessment of possible toxicity, allergenicity, and compositional analyses of key components.

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Date of authorization: 22/10/2018
Scope of authorization: Food and feed
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.):
Summary of the safety assessment (food safety):
A. STRP, PPSSD, BAI ASSESSMENT After thorough review of the technical documents submitted by the applicant, the assessors’ findings are as follows: 1. Host Organism (Cotton) Cotton is a source of key nutrients primarily oil and protein. The main product derived from cottonseed for human consumption is oil. The by-products from oil extraction, cottonseed cake and meal, contain significant amounts of protein making these suitable for feeding livestock. Cotton also contains anti-nutrients such as gossypol and cyclopropenoid fatty acids. Gossypol is the most notable of the terpenoid phytoalexins and was first isolated from the pigment glands in cottonseed. It is particularly toxic to non-ruminants and has male anti-fertility properties. Cylopropenoid fatty acids (CPFA), on the other hand, are associated with cottonseed oil. These CPFAs elevate the melting point of fats in animals fed whole cottonseed and cottonseed meal. The mechanism of action appears to be inhibition of desaturation of saturated fatty acids. In chickens, egg yolk discoloration and reduced hatchability are two detrimental effects. Although such is the case, processing of the oil eventually removes most of the gossypol while the deodorization step removes most of the CPFAs. Cottonseed, however, has not been considered as a common allergenic food. 2. Transgenic Plant GHB614 cotton contains a stably integrated gene, 2mepsps, which encodes a modified 5-enolpyruvylshikimate-3-phosphate synthase (2mEPSPS). The 2mEPSPS protein has decreased binding affinity for glyphosate, allowing it to maintain sufficient enzymatic activity in the presence of the herbicide thereby conferring GHB614 cotton tolerant to herbicide glyphosate. GHB614 has been approved in several countries such as Argentina, Australia/New Zealand, Brazil, Canada, EU, Japan, Korea, Mexico, Taiwan, and the USA. 3. Donor Organisms The 2mepsps coding sequence was produced by introducing two point mutations to the wild-type epsps gene cloned from corn (Zea mays) through in vitro DNA technologies. The resultant 2mEPSPS protein has a lower binding affinity for glyphosate, thus allowing sufficient enzyme activity for the plants to grow in the presence of glyphosate herbicide. History of safe use was attributed to corn and was not considered as a common allergenic food. Similarly, 2mEPSPS is not known to possess any property associated with toxicity or allergenicity. The developer provided sufficient description of all potentially inserted regulatory sequences. 4. Transformation System Cotton GHB14 was produced by Agrobacterium-mediated transformation system. The target of modification was the nucleus of recipient variety Coker 312 to ensure genetic stability of the glyphosate tolerance traits. 5. The Inserted DNA The GM Database from ISAAA showed that the main transgene, 2mepsps has been expressed in other approved GM crops including maize and soybean. Using the Southern Blot analysis, the single insertion, single copy integration in the event GHB614 was demonstrated and that the transferred DNA corresponds to the DNA configuration as designed in the pTEM2 plasmid. Further, bioinformatics analyses indicated that neither allergenic nor toxicological in silico findings were associated with the potential ORF polypeptides identified from GHB614 insertion site. The developer provided sufficient data and analyses that there is no plasmid backbone sequences present in GHB614 insert. 6. Genetic Stability To demonstrate the structural stability of Gossypium hirsutum transformation event GHB614, Southern blot analysis was performed on genomic DNA prepared from several individual plants of multiple generations. The analysis showed the presence of the expected 5’ and 3’ integration fragments in all tested transgenic DNA samples and thus demonstrated the structural stability of the Gossypium hirsutum transformation event GHB614 over different generations. Moreover, Three generations of backcrosses (BC1F1, BC2F1 and BC2F2) were tested for the presence of 2mepsps. Chi-Square Analysis was performed to determine the segregation of 2mepsps gene in the generations of backcrosses including F1 and F2. Results showed that the inheritance of 2mepsps from one generation to the other follows the Mendelian Law of Segregation. 7. Expressed Material The expression levels of 2mEPSPS protein in GHB614 cotton matrices were determined by enzyme-linked immune-sorbent assay (ELISA), as follows: • Leaves- 0.23 ug/g fresh weight – 14.89 ug/g fw • Stem- 0.62 ug/g fw – 2.55 ug/g fw • Root- 0.99 + 1.00 ug/g – 5.75 ug/g fw • Square- 5.1 ug/g fw – 5.6 ug/g fw • Apex- 5.25 ug/g fw – 5.69 ug/g fw • Pollen- 0.15 ug/g fw – 0.17 ug/g fw 8. Toxicological Assessment Digestibility. The test for stability of 2mEPSPS protein (produced in Escherichia coli ) in human simulated gastric fluid (SGF) showed the 2mEPSPS protein was degraded very rapidly in human SGF, within 30 seconds of incubation at 37°C in the presence of pepsin at pH1.2. The 2mEPSPS protein was degraded very rapidly (less than 30 seconds incubation) in human simulated intestinal fluid, in the presence of pancreatin, at pH 7.5. Heat Inactivation. The 2mEPSPS protein encoded by the 2mepsps gene was tested for stability at temperatures of 60, 75, 90°C for periods of 20, 30 or 60 minutes. The protein was examined by SDS-PAGE and by Western blot analysis. The results of the study showed that the 2mEPSPS protein is partially heat stable up to 90°C for 30 minutes and markedly degraded at 90°C for 30 minutes. Amino Acid Comparison. Based on the amino acid sequence comparison of 2mEPSPS conducted by the developer, 2mEPSPS in GHB614 cotton has no homology to any known toxins based on NCBI Non-Redundant Protein Sequence Database and Bayer Toxin Database. Acute Oral Gavage. Assessment of acute oral toxicity of 2mEPSPS in OF1 mice and the acute oral toxicity of bovine serum albumin (negative control) showed that there are no clinical signs or treatment-related effects on body weight in female OF1 mice after an oral administration of 2mEPSPS protein at 2,000 mg/kg body weight. Therefore, treatment with 2mEPSPS protein at 2,000 mg/kg body weight via the oral route did not produce signs of systemic toxicants in the OF1 female mice. Source of Test Protein. E. coli is the source of protein. 9. Allergenicity Assessment Amino Acid Comparison. FASTA searches showed no signifcant homology of 2mEPSPS to any known allergen. Prevalence in Food. The main cotton product consumed by humans is the cottonseed oil. Since the 2mEPSPS protein is not detected in oil products derived from seeds of GHB614 cotton, an intake of this recombinant protein via cottonseed food grade oil or products containing this oil quality is not possible. Processing using heat, for example cooking, high pressure steam, plus solvents, alkali treatments, will degrade the 2mEPSPS protein from GHB614 cotton. In untoasted cottonseed meal, the 2mEPSPS protein is still detected, while it cannot be detected anymore in toasted meal, crude oil or refined, deodorized oil; it cannot be detected either in lint or linters. Serum Screening. Serum screening was not performed. 10. Nutritional Data The components, which were selected for compositional and nutritional analyses, were proximate and fibre compounds, micro-nutrients such as minerals and vitamin E, the anti-nutrients total and free gossypol, cyclopropenoid fatty acids and phytic acid, the total amino acids, and the total fatty acids. For most of the analysed components no differences between the transgenic and non-transgenic control products were observed. If differences were noticed this has no nutritional impact, because all results obtained are comparable to reference ranges for commercial products, differences were only found for one product and not confirmed by the findings for the raw agricultural commodity or for other products, the differences in nutrient levels are too small for having a nutritional relevance or no uniform tendency in the difference to the non-transgenic products could be stated. Based on this statistical evaluation of the analytical data and an assessment of the nutritional impact of the different observations, the seeds from the glyphosate tolerant cotton event GHB614 and the products derived from them are found to be nutritionally equivalent to their traditional non-transgenic counterpart. There is no impact on the nutritional value of the cottonseeds as a result of the genetic modifications.
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Authorization expiration date (a blank field means there is no expiration date) October 21, 2023
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Organization/agency name (Full name):
Bureau of Plant Industry
Contact person name:
Geronima P. Eusebio
Website:
Physical full address:
San Andres St., Malate, Manila
Phone number:
632 404 0409 loc 203
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Country introduction:

In 1987, scientists from the University of the Philippines Los Banos (UPLB) and the International Rice Research Institute (IRRI), the Quarantine Officer of the Bureau of Plant Industry (BPI), and the Director for Crops of the Philippine Council for Agriculture, Forestry and Natural Resources Research and Development (PCARRD), recognizing the potential harm of the introduction of exotic species and genetic engineering, formed a committee and formulated the biosafety protocols and guidelines for genetic engineering and related research activities for UPLB and IRRI researchers. The committee went on to draft a Philippine biosafety policy, which was submitted to the Office of the President. On October 15, 1990, recognizing the potential for modern biotechnology both in improving the lives of the people and in creating hazards if not handled properly, President Corazon C. Aquino issued Executive Order 430 creating the National Committee on Biosafety of the Philippines (NCBP) that will formulate, review and amend national policy on biosafety and formulate guidelines on the conduct of activities on genetic engineering. The NCBP is comprised of representative of the Departments of Agriculture (DA); Environment and Natural Resources (DENR); Health (DOH); and Science and Technology (DOST), 4 scientists in biology, environmental science, social science and physical science; and 2 respected members of the community. On July 16, 2001, President Gloria Macapagal-Arroyo issued the Policy Statement on Modern Biotechnology, reiterating the government policy on promoting the safe and responsible use of modern biotechnology. On April 3, 2002, Department of Agriculture Administrative Order No. 8, Series of 2002 was issued implementing the guidelines for importation and release into the environment of Plants and Plant Products Derived from the Use of Modern Biotechnology. On March 17, 2006, President Gloria Macapagal-Arroyo issued Executive Order No.514 Establishing the National Biosafety Framework, prescribing guidelines for its implementation, reorganizing the National Committee on Biosafety of the Philippines, and for other purposes. On December 8, 2015, the Philippine Supreme Court declared DA AO8 null and void and any application for contained use, field testing, propagation and commercialization, and importation of GMOs was temporarily enjoined. In response to the nullification of DA AO8, the Technical Working Group composed of representatives from the Departments of Agriculture (DA), Science and Technology (DOST), Environment and Natural Resources (DENR), Health (DOH), and Interior and Local Government (DILG) drafted the Joint Department Circular No. 1, Series of 2016 (JDC No.1, S2016) titled 'Rules and Regulations for the Research and Development, Handling and Use, Transboundary Movement, Release into the Environment, and Management of Genetically-Modified Plant and Plant Products Derived from the Use of Modern Biotechnology'. There were series of meeting and five public consultations conducted before the JDC No.1, S2016 was approved and signed by the Secretaries of the abovementioned agencies on March 7, 2016 and took effect on April 15, 2016. Under this Circular, more government agencies were involved such as the Department of Science and Technology (DOST) to regulate applications for contained use and confined test of regulated articles; Department of Agriculture (DA) to evaluate applications for field trial, commercial propagation and transboundary movement of regulated articles; Department of Environment and Natural Resources (DENR) to evaluate environmental risks and impacts of regulated articles; Department of Health (DOH) to evaluate of environmental health impacts of regulated articles; and Department of the Interior and Local Government (DILG) to supervise public consultation during field trial.

 

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Stacked events:

Gene stacking in plants can be conferred either through genetic engineering or conventional breeding A full risk assessment as to food and feed or for processing shall be conducted to plant products carrying stacked genes conferred through genetic engineering or conventional breeding, where the individual traits have no prior approval for direct use as food and feed or processing from the Bureau of Plant Industry (BPI) A desktop or documentary risk assessment on the possible or expected interactions between the genes shall be conducted for stacked gene products with multiple traits conferred through conventional breeding and individual events granted prior approval by the Bureau of Plant Industry.

 

Plant Products Carrying Stacked Genes Conferred Through (a) Genetic Engineering or b) Conventional Breeding, with Individual Traits That Have No Prior Approval:

A full risk assessnent as to  food and feed or processing shall be conducted,consistent with Part V of AO No. 8,"Approval Process For the Importation of Regulated Articles for Direct Use as Food and Feed or For Processing for plant products with multiple traits conferred through:

(a) genetic engineering, or

(b) conventional breeding, where the individual traits have no prior approval from the Bureau of Plant Industry (BPI) for direct use as food and feed or processing.

Plant Products Carrying Stacked Genes Conferred through Conventional Breeding:

For plant products with multiple traits conferred through conventional breeding,with all individual events granted prior approval and included in the Approval Registry, a notlfication shall be submitted by the technology developer to the BPI, which shall conduct an evaluation in accordance with the relevant criteria in Annex I of this Memorandum Circular. The list of data contained in Annex I will not preclude the inclusion of other issues and concerns that will be raised by the BPI and the Scientific and Technical Review Panel (STRP) during the course of the desktop review.

Notificatlon Requirement for Plant Products Carrying Stacked Genes

All technology developers shall submit a notification to the Bureau of Plant Industry of their developed plant products carrying stacked genes and shall be required to comply with the relevant approval process listed above.

The Bureau of Plant Industry shall issue a certiflcate as to the approval of the stacked gene product and shall likewise include the transformation event in the official approval registry of plant products for food and feed or processing.

Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Bureau of Plant Industry 692 San Andres St, Malate, Manila 1004

Republic of Korea
Name of product applicant: Bayer Korea Ltd.
Summary of application:

Glyphosate herbicide tolerance

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Date of authorization: 25/10/2010
Scope of authorization: Food and feed
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.):
Summary of the safety assessment (food safety):
Please see the link below(in Korean).
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
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Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
Ministry of Food and Drug Safety
Contact person name:
Website:
Physical full address:
Osong Health Technology Administration Complex, 187, Osongsaengmyeong 2-ro, Osong-eup, Cheongwon-gun, Chungcheonbuk-do, 363-700, Korea
Phone number:
82-43-719-2360
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Stacked events:
Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:
Singapore
Name of product applicant: Bayer CropScience
Summary of application:

Apply for use as food, feed and for processing 

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Date of authorization: 02/11/2020
Scope of authorization: Food and feed
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.):
Summary of the safety assessment (food safety):
Cotton line GHB614 (BCS-GH002-5) is tolerant to glyphosate herbicide. It consists a modified epsps gene from corn, 2mepsps which produces 2mEPSPS enzyme protein with reduced sensitivity to glyphosate, thereby allowing continued enzymatic function in the presence of the glyphosate herbicide. Molecular characterization of cotton line GHB614 confirms the presence of one functional, intact copy of the 2mepsps gene at a single site in the plant genome. The new genetic trait is stably incorporated into the cotton genome and is transferred to subsequent generations in a normal pattern of inheritance. The 2mEPSPS protein is unlikely to be toxic or allergenic to humans. Composition analyses showed that the key constituents in food derived from cotton line GHB614 are equivalent to food from conventional varieties of cotton. Food derived from cotton line GHB614 is as safe as food derived from conventionally produced cotton varieties.
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Relevant links to documents and information prepared by the competent authority responsible for the safety assessment:
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Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
Singapore Food Agency (SFA)
Contact person name:
Dr Tan Yong Quan
Website:
Physical full address:
52 Jurong Gateway Road 14-01 JEM Office Tower Singapore 608550
Phone number:
(65)68052750
Fax number:
Country introduction:

The Singapore Food Agency (SFA) is a Statutory Board established under the Ministry of Sustainability and the Environment (MSE) to oversee food safety and security. SFA’s mission is to ensure and secure a supply of safe food.  SFA adopts a risk-based approach to food safety. Foods with foodborne hazards that may pose potential food safety risks to consumers are subjected to more stringent checks, regardless of their country of origin. SFA has in place an integrated system to ensure that both imported and domestically produced foods are safe for consumption.  The system comprises control measures such as source accreditation, inspection and surveillance of food, laboratory analysis, food legislation and recall of food products, which safeguard food safety from farm to fork.

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Stacked events:

More information on the guidelines for the safety assessment of stacked events can be found on GMAC’s website:

http://www.gmac.sg/Index_Singapore_Guidelines_on_the_Release_of_Agriculture_Related_GMOs.html

Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Singapore Food Agency (SFA)

United States of America
Name of product applicant: Bayer CropScience USA LP
Summary of application:
Cotton
Trait 1 Added Protein: Double-mutant 5-Enolpyruvylshikimate 3-phosphate synthase (2mEPSPS)
Source: Zea mays
Intended Effect: Tolerance to the herbicide glyphosate
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Date of authorization: 29/09/2008
Scope of authorization: Food and feed
Links to the information on the same product in other databases maintained by relevant international organizations, as appropriate. (We recommend providing links to only those databases to which your country has officially contributed.):
Summary of the safety assessment (food safety):
Please consult the FDA website links below.
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Where detection method protocols and appropriate reference material (non-viable, or in certain circumstances, viable) suitable for low-level situation may be obtained:
Relevant links to documents and information prepared by the competent authority responsible for the safety assessment: FDA's webpage regarding this variety
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Authorization expiration date (a blank field means there is no expiration date)
E-mail:
Organization/agency name (Full name):
Food and Drug Administration
Contact person name:
Jason Dietz
Website:
Physical full address:
5100 Paint Branch Parkway, College Park MD 20740
Phone number:
240-402-2282
Fax number:
Country introduction:

The United States is currently in the process of populating this database. The Food and Drug Administration regulates food and feed (food for humans and animals) from genetically engineered crops in conjunction with the Environmental Protection Agency (EPA). EPA regulates pesticides, including those that are plant incorporated protectants genetically engineered into food crops, to make sure that pesticide residues are safe for human and animal consumption and do not pose unreasonable risks of harm to human health or the environment. FDA In the Federal Register of May 29, 1992 (57 FR 22984), FDA published its "Statement of Policy: Foods Derived from New Plant Varieties" (the 1992 policy). The 1992 policy clarified the agency's interpretation of the application of the Federal Food, Drug, and Cosmetic Act with respect to human and animal foods derived from new plant varieties and provided guidance to industry on scientific and regulatory issues related to these foods. The 1992 policy applied to all foods derived from all new plant varieties, including varieties that are developed using genetic engineering (also known as recombinant deoxyribonucleic acid (rDNA) technology). In the 1992 policy, FDA recommended that developers consult with FDA about foods from genetically engineered plants under development and developers have routinely done so. In June 1996, FDA provided additional guidance to industry on procedures for these consultations (the consultation procedures). These procedures describe a process in which a developer who intends to commercialize food from a genetically engineered plant meets with the agency to identify and discuss relevant safety, nutritional, or other regulatory issues regarding the genetically engineered food and then submits to FDA a summary of its scientific and regulatory assessment of the food. FDA evaluates the submission and if FDA has questions about the summary provided, it requests clarification from the developer. At the conclusion of the consultation FDA responds to the developer by letter. The approach to the safety assessment of genetically engineered food recommended by FDA during consultations, including data and information evaluated, is consistent with that described in the Codex Alimentarius Guideline for the Conduct of Food Safety Assessment of Foods Derived from Recombinant-DNA Plants. EPA The safe use of pesticidal substances is regulated by EPA. Food from a genetically engineered plant that is the subject of a consultation with FDA may contain an introduced pesticidal substance, also known as a plant-incorporated protectant (PIP), that is subject to food (food for humans and animals) safety and environmental review by EPA. PIPs are pesticidal substances produced by plants and the genetic material necessary for the plant to produce the substance. Both the PIP protein and its genetic material are regulated by EPA. When assessing the potential risks of PIPs, EPA requires studies examining numerous factors, such as risks to human health, non-target organisms and the environment, potential for gene flow, and insect resistance management plans, if needed. In regulating PIPs, decisions are based on scientific standards and input from academia, industry, other Federal agencies, and the public. Before the first PIP product was registered in 1995, EPA required that PIP products be thoroughly tested against human safety standards before they were used on human food and livestock feed crops. EPA scientists assessed a wide variety of potential effects associated with the use of PIPs, including toxicity, and allergenicity. These potential effects were evaluated in light of the public's potential exposures to these pesticides, taking into account all potential combined sources of the exposure (food, drinking water, etc.) to determine the likelihood that a person exposed at these levels would be predisposed to a health risk. Based on its reviews of the scientific studies and often peer reviews by the Federal Insecticide, Fungicide and Rodenticide Scientific Advisory Panel, EPA determined that these genetically engineered PIP products, when used in accordance with approved label directions and use restrictions, would not pose unreasonable risk to human health and the environment during their time-limited registration.

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Stacked events:

Stacked events that are each plant incorporated protectants, as defined by the Environmental Protection Agency, must be registered by the Envriornmental Protection Agency before they can be commercialized.  Food/feed safety asssessment of single events are generally sufficient to ensure the safety of food/feed from stacked events.   

Contact details of the competent authority(s) responsible for the safety assessment and the product applicant:

Food and Drug Administration ([email protected]); Environmental Protection Agency