Seeds modified to produce:	Industrial products
Stearic acid (40%)	Margarine, cocoa butter substitute
Lauric acid (40-60%)	Detergents
Oleic acid (80%)	Food, lubricants, ink
Petroselinic acid	Polymers, detergents
Jojoba wax	Cosmetics, lubricants
Myrisatic acid (40%)	Detergents, soap
Erucic acid (90%)	Polymers, cosmetics, ink
Ricinoleic acid	Lubricants, plasticisers, pharmaceuticals
Polyhydroxybutyrate	Biodegradable plastics

Taken from Murphy et al TIBTECH 14 206-213 (1996).

  The only economically significant route for the disposal of the seedmeal remaining after the extraction of oil from oilseed plants is as animal feed. At present feed compounders or those farmers who mix feed on the farm treat all batches of oilseed meals as equivalent. This will no longer be possible if seedmeal derived from GM rape, or other commonly used by-products of the extraction industries (eg cottonseed meal) derived from other GM crops, become commonplace. Not only will there be appreciable issues for example if the lauric acid content of meat or milk rises, but there is clearly a demand that GM foods should be kept and labelled separately. Lauric acid is known to be a potent stimulator of blood cholesterol in man and erucic acid is also a well-known toxicant. Feed producers will need to accurately source their raw ingredients to ensure that residues of highly potent biological agents or toxic chemicals (eg erucic acid in modified rape) are absent. We doubt whether it will be possible to keep all GM foods completely separated in 10 years' time but if needed in the animal feed business a complete transformation of agricultural practice will be required. Risk management measures will have to be introduced in other countries even if such crops are not to be grown in Europe in the foreseeable future. The animal feed trade, like the food industry, is a global enterprise that sources its ingredients from all over the world. In the absence of any risk management strategy, traditional routes for the disposal of some crop by-products may have to be reconsidered.

8.5 Conclusions on some new proposals for better safety scrutiny

  The current FDA approaches to the sanctioning of new GM crops will prove inadequate when assessing the large number of different genetic traits now being tested in a variety of new plant hosts. There is therefore a need to develop more effective and appropriate screening methods to alert companies and government agencies to the unexpected consequences of the often random insertion of genetic traits into plants. The proposed use of differential display techniques to monitor the induction of specific genes, the development of proteomics to assess the range and nature of new proteins and metabolic screening for unusual metabolite accumulation or loss are simply examples of how to assess the impact of genetic manipulations without making assumptions about the outcome. The issues of allergy, gastrointestinal and metabolic effects of lectins and other transcribed genes remain. The expansion of GM industrial crops presents major new challenges if consumers seek to ensure a complete separation of GM crops on a long term basis and ensure that disadvantageous by-products do not enter the food chain. There is a need to develop anad apply new scientific approaches in the safety evaluation of GMOs. This is not only appropriate scientifically but should go some way towards allaying public concern about the safety of these GMO developments.

9. EVENTS RELATING TO DR PUSZTAI

  Dr Arpad Pusztai is a distinguished expert in lectins, ie plant proteins of complex and varied structure with a very broad range of actions. In plants, lectins seem to act by deterring pests: lectins are frequently found to damage the intestine of insects, nematodes etc. Therefore they have become popular with plant molecular biologists since the insertion of a lectin into a major crop may enhance its pest resistance and reduce the need for spraying with alternative pesticides. Dr Pusztai showed years ago, however, that some lectins, eg the phytohaemagglutinin lectin (PHA) obtained from red kidney beans can induce very marked intestinal damage to the mammalian gut. This is why traditionally red kidney beans are soaked and well cooked before consumption; severe diarrhoea may otherwise occur. Pusztai's major concern therefore has been that plant molecular biologists will introduce lectins which damage the mammalian gut as well as pests. He therefore rightly stresses the need for better discrimination techniques to evaluate the well recognised specific interaction of particular lectins with precise carbohydrate structures in the mammalian intestine. Lectins' subsequent effects on intestinal responses, turnover and immunological function are at present unpredictable. Some lectins are also absorbed and may have unusual metabolic effects. Others induce pancreatic swelling, excess replication and, when fed chronically, pancreatic tumour formation.

  Some years ago we took Dr Pusztai's concerns to the DoH/MAFF Advisory Committee on Novel Foods and Processes at a time when it was evolving new schemes for evaluating new foods and novel food processes. An additional line of enquiry was therefore inserted to alert plant molecular biologists to the potential impact of new gene inserts on mammalian function. The modified scheme was then also taken by Philip James by virtue of his joint committee membership to a European level when the EU was evolving its own scheme. The EU scheme in practice is very heavily based on the UK approach.

  Pusztai remains convinced (and we agree) that adequate in vivo tests need to be developed before a new GM crop with a lectin insert is released for either animal or human consumption. Pusztai's views have been published and are widely recognised. These views led the Scottish Office to establish in 1995 a new research programme involving Dr Gatehouse, a plant molecular biologist at the University of Durham, the Scottish Crop Research Institute (SCRI) and Dr Pusztai. The plan was for Dr Gatehouse to insert three different lectins; PHA from red kidney beans, ConA from the jack bean and GNA from the snowdrop bulb into potatoes. This crop was chosen because SCRI have exceptional experience of both potato genetics and how to grow new varieties and GMOs under highly controlled conditions. The potato was also chosen because it could be used with Dr Pusztai's nutritional expertise in substantial quantity in rat diets. The plan was to see how to develop new test schemes; both PHA and ConA are well-recognised lectins with both intestinal and immunostimulatory effects whereas Dr Pusztai's previous published analyses with purified GNA led him to conclude that GNA was harmless. This research was obviously of a strategic nature, ie to develop new screening methods and was not designed to specify whether these potato lines should enter the market.

9.1 The World in Action programme

  Dr Pusztai had aired his views on a Newsnight programme in early 1998 and had been involved in a Scottish TV programme dominated by Rowett Institute research which took a cautious look at GM safety issues. When World in Action requested his involvement Dr Pusztai was given permission to take part provided he maintained his published cautionary approach to the use of lectins and did not release any unpublished material.

  Given the recognised approach of World in Action particular care was taken to forewarn Dr Pusztai of expected problems but Dr Pusztai reassured the Institute Director, Philip James, both after filming and again on having the transcript read to him, that no unpublished material had been used and that no problems were expected. Yet the weekend before the programme was broadcast on 10 August, Dr Pusztai was bombarded at home by enquiries, praise and criticisms from all over the world. This intense media blitz stemmed from a pre-broadcast press release by World in Action with or without additional briefing.

9.2 10 August

  On discovering extraordinary and intense governmental, industrial, NGO and media interest in data from unpublished Con A transgenic potato experiments, the Directors relieved Dr Pusztai of media involvement and tried to quell the release of further unpublished data by issuing a press release after briefing Dr Pusztai. Emphasis was laid on the experimental nature of the approach, the long-recognised actions of ConA and that the transgenic ConA potato diet had unsurprisingly led to impaired growth and immune depression. We emphasised that no further unpublished data would be issued but all relevant information would be made available to policy makers. We then had to cope with intense scientific criticism about the release of unpublished data.

  Dr Pusztai's collaborators from two major research programmes also dissociated themselves from his discussion of experiments and concepts which had not been agreed and sought new collaborative arrangements with the Institute. Finally the Directors were asked by Dr Pusztai to delay inspection of all the available data until the following day when Dr Pusztai's assistant returned to the Institute.

9.3 11 August

  The media's intense interest in Dr Pusztai's revelations continued and featured as the main news story on many TV and radio channels throughout the world. By 5 p.m., however, after we had reviewed all the available new data, Dr Pusztai's assistants informed us that in fact no transgenic ConA studies had been conducted: it would seem, therefore, that Dr Pusztai was confused about which studies had actually been completed. Furthermore, Dr Pusztai and his assistants agreed that growth impairment had not been found in the long-term (110 day) feeding studies with GNA transgenic potatoes. Unfortunately the 110 day GNA immune studies were still incomplete at this time and therefore results of these experiments could not have been available when filming for World in Action took place in June. The Audit Committee has subsequently concluded that three errors were transmitted in the World in Action programme and these errors led, in conjunction with Dr Pusztai's media interviews over the weekend, to misleading claims being made about the health hazards of transgenic lectin use.

9.4 12 August

  As a result of these developments, Philip James instigated an independent audit using Medical Research Council guidelines to protect Dr Pusztai from the charge that he had concocted data and to settle the apparent confusion about exactly what experiments had been done and what conclusions were appropriate. Dr Pusztai was temporarily suspended only from his lectin work and was encouraged to continue with his other work within the Institute. The Audit Report was produced on 22 August and concluded that the assistants' account of the experiments conducted was correct. Only GNA studies had been carried out with transgenic potatoes. There was no slowing of growth in the rats on the GNA potato diet. In addition, the results of the immune studies were far too variable to draw any reliable conclusions. Dr Pusztai was asked to comment on the Audit Report and to write up all the studies which had been completed in the proper scientific manner, ie with publication, after peer review, in appropriate scientific journals.

9.5 Dr Pusztai's contract

  Dr Pusztai's post-retirement contract was very unusual. He should have retired aged 60 years on 8th September 1990, but we devised a scheme whereby we gave him annual Senior Research Fellowship contracts. His pension was supplemented to bring his total remuneration approximately up to his previous salary level. Annual reviews were made until Dr Pusztai was 65 years when he was still working intensely hard with major international collaborators and EU, Scottish Office and industrial projects. At that stage he wondered whether he could maintain his work rate for more than a further 2-3 years. It was agreed that he would certainly retire at the age of 70, if he had not done so before. Given the events of 11 August, the views of his collaborators and the possibility that the Institute would be challenged to hold another audit should Dr Pusztai generate controversial research inimical to either NGO or big industrial interests, we decided that his current post-retirement contract should not be renewed. He was therefore informed that he would be retiring on 31 December, 1998. He was also encouraged to continue his lecturing commitments and special arrangements were made to allow him to continue as a consultant with measures to protect his financial interests. Therefore, although he was retiring during the course of his 69th year, he still had the opportunity to continue to be involved. He was neither "sacked" nor "prematurely retired".

  We also sought to re-establish Dr Pusztai's reputation by asking him to produce full scientific papers. He was also informed that attempts to justify himself by discussing unpublished data would not be in his own interests. Dr Pusztai was also informed that if his peer reviewed and published work showed that the Audit Committee had been wrong in its judgements, this would of course be accepted by the Rowett Research Institute. A press conference was also offered if this proved helpful. Thus the challenge that we "gagged" Dr Pusztai related to our insistence that he only discuss published work when speaking to the media. His research collaborators would also have to be consulted and agree to any public statements.

9.6 Dr Pusztai's Alternative Report

  Dr Pusztai did not in the end produce a response to the Audit Report but what be termed an "Alternative Report" on 22 October. This he sought to have published. Dr Pusztai disputed two conclusions of the Audit Report relating to (a) what is termed substantial equivalence and (b) whether or not organ weight changes had occurred. Dr Pusztai also provided further new unpublished data from a study which had still been in progress at the time the Audit Committee's analysis of completed work. Dr Pusztai's Alternative Report was sent to the members of the Audit Committee and considered by the Rowett's Governing Body who invited Dr Pusztai to set out his views to their Scientific Subcommittee prior to his publishing.

  We considered that this Alternative Report was unsuitable for publication as we sought to maintain the almost universally accepted policy of not releasing unpublished data. The general reader would also have found it exceptionally difficult to integrate the original Audit Report and all its data with the counterclaims made by Dr Pusztai. We considered it in Dr Pusztai's interests for him to set out the whole sequence of experiments in a coherent manner for publication.

  We agreed with the collaborating organisations the precise wording of the Rowett's response to the Audit Report for a House of Lords Committee's hearing on GMOs due on 28 October, but indicated to the Hearing that Dr Pusztai had further views which would be made public in due course. We also devised a mechanism whereby the conclusions of the Audit Report could be released but the extensive experimental data would only be made available on personal request. This allowed both a policy of openness in terms of issues of intense public interest and yet preserved the possibility for Dr Pusztai of a full publication of his work. We confidently expected to have an integrated account of these studies by the end of 1998 since Dr Pusztai has been prolific in producing with collaborators an average of 22 papers per year over the last five years.

9.7 Recent events

  Almost one month ago we became aware of claims made by colleagues and friends of Dr Pusztai on the Internet suggesting that it was the fundamental mechanism involving the use of a viral promoter to insert the lectin into a plant which was a problem. It was claimed that Dr Pusztai's transgenic GNA studies had now shown this by virtue of Dr Stan Ewen's histological analyses made in October 1998, ie weeks after the World in Action programme. We requested information on this from Dr Ewen, a long time collaborator of Dr Pusztai's, but first saw data on the Channel 4 news on 11 February. This had been made public at a press conference held in the House of Commons. Further details then emerged in an article in The Guardian.

  Given the much publicised press conference and the seeming need of many media channels to find dramatic evidence of food dangers, political manipulation or industrial pressure, we reluctantly decided to change tack and release the Dr Pusztai's Alternative Report. We also released Dr Pusztai from any restrictions on his analyses of his unpublished lectin work since no purpose was being served by our continuing request for dealing with these issues in the proper scientific manner.

  At no time has the Rowett Research Institute been under any political, industrial or other pressures. It has sought throughout to maintain the most responsible approach possible from a public interest standpoint.

9.8 Conclusions relating to Dr Pusztai

  Dr Pusztai's concerns about the need for devising new safety tests for transgenic lectins are, in our view, valid. We judge, however, that his experiments to date are far too crude and preliminary to justify any claims for novel findings of either lectin-related or general biotechnological significance.

1 March 1999