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Sunday, 17th April, 2005
 
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Backgrounder on the Safety Assessment and Regulatory Status of MON 863 YieldGard® Rootworm Maize

Background: The rootworm issue
Corn rootworm is one of the most pernicious pests affecting maize crops around the world. Corn rootworm larvae damage maize by feeding on the roots, reducing the ability of the plant to absorb water and nutrients from soil and causing harvesting difficulties due to plant lodging. The US Department of Agriculture estimates that this pest causes $1 billion in lost revenue annually to the US maize crop. An estimated 5.7 million hectares of maize in the US are treated annually with chemical insecticides to control this pest.

What is MON 863 YieldGard® Rootworm maize?
As an alternative to chemical insecticides, YieldGard® Rootworm contains a protein from Bacillus thuringiensis (Bt), a common soil microbe that specifically targets corn rootworm larvae, allowing the corn plant to naturally protect its roots against the damaging corn rootworm.

The use of biological insect control is more environmentally sustainable than the use of pesticides. Bt proteins have been used for pest control for more than 40 years by farmers worldwide, including organic farmers.

MON863 YieldGard® Rootworm has been grown commercially in the United States and Canada since 2003, and has been approved for import and food use in many countries around the world, including Japan, Korea, Taiwan, the Philippines, Russia and Mexico.

Details on MON 863 maize can be found at http://www.essentialbiosafety.info/main.php.

Regulatory status of MON 863 maize in the EU Regulatory approval for the import and use of biotech crops in the EU requires a number of steps involving review by more than one hundred independent scientists acting on behalf of the European Commission and Member States' governments. The regulatory steps that MON 863 has undergone in the EU are described below.

In July 2002, Monsanto submitted an application for import of MON 863 maize (excluding cultivation) under Directive 90/220/EEC to Germany, the country acting as Rapporteur for this file. This submission, which contained the Rat 90-day Subchronic Dietary Feeding Study conducted by a third party (1), was then updated to fulfill the new 2001/18/EC requirements. Germany issued a positive Initial Assessment Report (2), which was forwarded to the EU Member States for review in April 2003.

In parallel, the application was opened for public review and comment on 05 May 2003.

Monsanto submitted an application under the novel food and novel food ingredients Regulation (EC) N° 258/97, also to Germany as lead Member State, in July 2002. Germany issued an Initial Assessment Report, which was forwarded to the EU Member States for review in June 2003. Answers to additional questions, comments and reasoned objections from some Member States were submitted to all Member States in September 2003.

In order to provide further independent assessment, Monsanto commissioned a formal Study and Pathology, Peer review (7). This was a voluntary activity on behalf of Monsanto in which two highly experienced independent veterinary pathologists, one having particular expertise in relation to renal histopathology, conducted a Peer Review of this study to arrive at a scientific consensus on whether there were any toxicologically significant findings in this study. After detailed review and discussion, the experts concluded, consistent with the original report, "that dietary administration of MON 863 corn did not induce toxic effects in the kidneys of rats".

The European Foods Standards Authority (EFSA) evaluated the complete dossier and adopted a positive scientific opinion on 02 April 2004, concluding, "the placing on the market of MON 863 is unlikely to have an adverse effect on human and animal health or the environment in the context of its proposed use." (http://www.efsa.eu.int/) (3).

Regulators at some Member States raised questions about the studies submitted as part of Monsanto's applications, and this is a normal part of the regulatory process. Monsanto has addressed these questions and performed additional scientific analysis as necessary. As a result, European competent authorities now concur that MON 863 YieldGard Rootworm maize is as safe as conventional maize for human and animal health and the environment.

The next stage in the process is a vote on MON 863 by EU Member States.

Chronology and Summary of opinions on OECD 408.
Rat 90-day Dietary Feeding Study Covance 90 Day Rat Dietary Subchronic Comparison Study with MON 863 Corn in Rats Covance Study No. 6l03-293 17th December 2002

Reference 1
"Toxicological parameters evaluated were survival, clinical signs, body weights, food consumption, clinical pathology, organ weights, and macroscopic and microscopic pathology. There were no test article related changes in any of the aforementioned toxicological parameters. The response of rats fed either 11 or 33% w/w corn event MON 863 in the diet was comparable to rats fed diets containing the nontransgenic control line LH82xA634 and corn from six commercial nontransgenic reference control varieties."
Assessment Report of the Robert Koch Institut in Accordance with Directive 2001/18/EC 8th April 2003

Reference 2
See Section 3.5.2.1 Feeding Studies using MON 863 Maize Kernels - Subchronic Feeding Study "From this extensive study, it can be deduced that even after long-term oral exposure to MON 863 Maize Kernels no harmful effects are to be expected".
EFSA - Novel Food Assessment 258/97 Opinion 02/04/2004

Reference 3
"MON 863 will not have an adverse effect on human and animal health."
EFSA - Directive 2001/18.EC Press Release 19/04/2004

Reference 3a
MON 863 "as safe as conventional maize'
AFSSA (French Food Safety Agency) 2nd December 2003

Reference 4
Stated, "…equivalence in chemical and nutritional composition" of MON 863 with comparable varieties, and that "the human consumption of grains and products derived from MON 863 maize, does not pose any nutritional risk."
CGB 28/10/2003 05/11/2003 CGB requested more precise interpretation of selected data

Reference 5
"In the absence of additional confirmatory studies, […] the committee of the CGB is not able to definitively conclude on the absence of any risk to animal health"
Monsanto 24/05/2004 Supplemental analysis in response to CGB request

Reference 6
"…the weight of evidence supports a conclusion that there are no MON 863 induced adverse effects…"
Pathology Peer Review - Seventh Wave - 003 - RS-04 Retrospective Evaluation of Renal Tissues and data from Monsanto Co. Study CV - 2000 - 260 (MSL 18175): a 13 week Rat Feeding Study with MON 863 Corn 11/08/2004 Peer Review in response to CGB request

Reference 7
"…that dietary administration of MON 863 com did not induce toxic effects in the kidneys of rats"

References

(1) 13 week Dietary Subchronic Comparison Study with MON 863 Corn in Rats Preceded by a 1 - Week Baseline Food Consumption Determination with PMI Certified Rodent Diet #5002. (OECD Protocol 408) Covance Study No. 6l03-293, issued 17th December 2002

(2) Assessment Report of the Robert Koch Institut in Accordance with Directive 2001/18/EC, Insect -Resistant Maize MON 863 and MON 863 x MON 810, 8th April 2003 (draft translation); http://gmoinfo.jrc.it/gmc_browse.asp Assessment Report PDF file

(3) Opinion of the Scientific Panel on Genetically Modified Organisms on a request from the Commission related to the safety of foods and food ingredients derived from insect-protected genetically modified maize MON 863 and MON 863 x MON 810, for which a request for placing on the market was submitted under Article 4 of the Novel Food Regulation (EC) No 258/97 by Monsanto (Question No EFSA - Q - 2003 - 121) Opinion Adopted on 2nd April 2004

(3a) Opinion of the Scientific Panel on Genetically Modified Organisms on a request from the Commission related to the Notification (Reference C/DE/02/9) for the placing on the market of insect-protected genetically modified maize MON 863 and MON 863 x MON 810, for import and processing, under Part C of Directive 2001/18/EC from Monsanto (Question No EFSA-Q-2003-089) Opinion Adopted on 2nd April 2004

(4) AFSSA (French Food Safety Agency) Opinion dated 2nd December 2003 http://www.afssa.fr/Object.asp?IdObj=-4&Pge=0&search=MON%20863&cwSID=E95C8119B0E544B8A64296D770CA52B5&AID=0

(5) CGB (Commission du Genie Biomoleculaire) Opinion dated 28th October 2003 … http://ogm.agriculture.gouv.fr/mise_marche/avis_scientifiques/avis_scientifique_2003.htm

(6) Supplemental Analysis of Selected Findings on the Rat 90-day Feeding Study with MON 863 Maize, Report MSL - 18175; Hammond, B.G. and Ward, D.P., Monsanto Co., USA, 24th May 2004

(7) Retrospective Evaluation of Renal Tissues and data from Monsanto Co. Study CV - 2000 - 260 (MSL 18175): a 13 week Rat Feeding Study with MON 863 Corn, (Covance Laboratories Study No 6103-293)

Click here to read the MON 863 Maize 90-Day Rat Feeding Study Design and Conduct Fact Sheet.

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