Read Dr. Heinemann's submission to FSANZ Chris Teo-Sherrell interviewed Dr. Jack Heinemann of Canterbury University's Centre for Integrated Research in Biosafety to learn more about his concerns regarding Monsanto's high lysine corn.
Greens: Why are you concerned about high lysine corn?
Heinemann: High-lysine corn was designed for use as animal feed. The corn would be a precedent-setting novel human food because it has been designed to be substantially different from conventional corn by the accumulation of high levels of the amino acid lysine. Monsanto seeks to amend the Food Code because it does not believe that it can prevent contamination of human food with this corn grown for animal feed. However, the law will not restrict the amount of this corn that can be in human food once the Code is amended. Therefore, the corn must be as safe as conventional corn at any concentration that is normal for humans to consume corn. We believe that there is an exceptional chance that it is not.
Greens: Why is high lysine corn potentially dangerous?
Heinemann: It is not the absolute amount of lysine that is concerning here, but the unusually high concentration of lysine in the same place as all the sugars that are found in corn. This variety of corn, unfortunately, also has extremely high levels of sugar: up to 4 times the amount of sugar in sweet corn. Lysine as an amino acid or as a normal component of protein can react with sugars to form what are called "advanced glycoxidation endproducts" (AGEs). Dietary AGEs have been implicated in causing the symptoms of Alzheimer's, diabetes (and related autoimmunity), cancer, heart disease and kidney disease. Usually, people with susceptibility to these diseases, or that may suffer from them, are encouraged to eat foods low in compounds that produce AGEs, such as fruits and vegetables. We are concerned that by converting corn into a relatively enriched source of AGEs, everyone loses an important source of nutrition that does not increase our risk for these diseases.
To this, FSANZ says that the level of lysine and some of the breakdown products in high lysine corn are not higher than many other common foods such as fish and lentils. We have provided evidence to FSANZ showing that foods naturally high in lysine have extremely low levels of free lysine. This is important because not all AGEs are the same. The AGEs formed by reaction with free lysine and its breakdown products may have very different biological activities than AGEs produced by reactions between proteins (with incorporated lysine) and sugar. Each breakdown product would also potentially create a unique species of AGE.
Greens: Isn't lysine a natural amino acid that is required in the diets of both humans and animals?
Heinemann: Yes, lysine is a natural amino acid and we and animals must acquire it from our diets to be healthy. Foods such as meat and lentils are high in proteins that contain lysine. When we eat such foods, we break down the proteins and scavenge the lysine for use in building our own proteins. And this is the key point. The way high lysine corn is genetically modified causes it to accumulate free lysine, not just proteins that are rich in lysine.
There are also some conventional lines of corn that have high lysine. However, there are zero reports in the literature (that we could find) that these lines accumulate FREE LYSINE (50 times higher in LY038) or the undesirable lysine breakdown products seen in LY038 (up to 110 times higher in LY038). Moreover, mutant varieties of corn rarely accumulate lysine in the grain (the part we eat) because of an up-regulation in biochemical pathways that eliminate lysine (via the breakdown products I've been mentioning). Probably under normal conditions, lysine and its breakdown products are completely converted into benign compounds, but in high lysine corn there is too much lysine for these biochemical pathways to remove all lysine and the intermediate breakdown products. Those pathways just get overwhelmed.
Each of the lysine breakdown products in high lysine corn has its own potential toxicity whether or not it also reacts with sugar to create AGEs. There is just too little science and too much uncertainty in this area to dismiss the potential for LY038 to be harmful as a human food.
Greens: Monsanto did do a study where they fed chickens high lysine corn and reported no ill effects. Why isn't this sufficient to convince you that the corn is okay?
Heinemann: There are several problems with drawing conclusions of safety from those kinds of experiments. First, the corn was raw and not cooked or processed, the way we eat corn. AGEs form under the temperatures and pressures of cooking and processing. Therefore, the primary threat to humans will only be revealed by studies using this corn after it has been cooked or processed.
Second, that study was clearly an animal production study and measurements pertinent to human health were not undertaken. Interestingly, however, there was an unexplained negative effect on broiler chicks during the first 21 days they are fed this corn (even in raw form), that FSANZ has never explained to us.
Third, chickens are physiologically very different to humans and hence cannot be used as a suitable health model for humans. We provided FSANZ with sound studies showing that for this type of food hazard the best model animals are rats and pigs.
Greens: Is the problem that this is GE corn or that it has high lysine?
Heinemann: A primary safety issue in this case is lysine and its breakdown products (which are at unprecedented concentrations compared to conventional corn), but they are not the only problems we found with the risk assessment. Other important problems had to do with the corn being GE. For example, a. the molecular and compositional comparisons required for recombinant crop plants were found by our Centre to be deeply flawed and well below the standard recommended by international food safety agencies. b. We also found flaws in the analysis used to evaluate the recombinant protein in this corn as an allergen. The studies accepted by the Authority are not studies that have been approved through international consensus agreement (WHO/FAO standards). c. The bioinformatics analysis used to search for allergens appears to have used the incorrect amino acid sequence of the protein. d. There were significant internal inconsistencies with the Southern blots used to demonstrate that LY038 has a single intact insertion. This list goes on.
We also have serious concerns with the level of apparent industry influence on the FSANZ review process. According to correspondence from Monsanto, it believed that it was being asked to provide support to a FSANZ effort to dismiss our concerns. Monsanto staff have stated that "FSANZ will be seeking outside expert opinion on these claims [made in the Centre's submission] here in Australia as they do not feel they have the appropriate expertise in-house to answer these claims...and [FSANZ] feel that it is critical for Monsanto to be involved in this process" (our emphasis). It appears that Monsanto does not believe FSANZ has confidence in its ability to comprehensively review the safety of GM foods and that FSANZ has asked Monsanto to assist FSANZ in that task. Consistent with this interpretation is a request (14 March 2005) from Paul Brent (FSANZ) that Bronwyn Dixon (FSANZ) "get back to" Bertuch (Monsanto) "if there are [other concerns FSANZ has with the Centre's submission that] we might need help with." Further, FSANZ thanks Monsanto for drafting a reply to our submission, saying "Dear Beth, Thank you for this information. It should be a big help when I respond to the [Centre]." This creates fundamental questions about Monsanto's relationship with FSANZ.
Greens: What is the Centre for Integrated Research in Biosafety (INBI) and why is it interested in high lysine corn?
Heinemann: INBI is a multidisciplinary research centre with a focus on the impacts of biotechnology. INBI (previously the New Zealand Institute of Gene Ecology) is composed of researchers from the natural, social and political sciences and those with research interests in law, culture and gender.
Our work is funded by the Government of Norway as part of an international effort to raise global capacity for biosafety. We have special responsibility for developing tools that improve safety assessments of genetically modified organisms. These tools are hoped to be friendly ways for citizens, government regulators and scientists with other specialities to access the best available and latest research and apply it to hazard identification. This is the first step in a risk assessment and is necessary to be done well in order to capture what ultimately any particular society will come to view as acceptable or unacceptable impacts of some modified organisms in their particular environment and for their particular culture.
The tool will be available for free public use, but is being optimised for those countries, like New Zealand, that have ratified the Cartagena Protocol on Biosafety. That international treaty allows countries to accept or forbid the import and export of living genetically modified organisms after they have conducted a scientific risk assessment.
Our work on Monsanto's high lysine corn began as a training exercise for our team building the tool. After we conducted our independent assessment of the product, we felt that Food Standards Australia New Zealand and the New Zealand Food Safety Authority failed to identify key hazards.
