Summary of the safety assessment (food safety): |
The
organism analyzed displays tolerance to glyphosate and gluphosinate ammonium herbicides,
granted by genes 2mepsps and bar, respectively. Both events have already been commercially
released by CTNBio by Technical Opinion nº 1521/2008 (published in the Federal Official
Gazette of 09.04.2008), related to commercial release of genetically modified cotton tolerant
to gluphosinate ammonium herbicide (LibertyLink cotton, Event LLCotton24) and Technical
Opinion nº 2754 (published in the Federal Official Gazette nº 241, of 12.27.2010, related to
commercial release of genetically modified cotton tolerant to the glyphosate herbicide (GlyTol
cotton, Event GHB614). Assessment of the results for all tests indicated that
GlyTol x LibertyLink is held as substantially equivalent to other cotton varieties. Restricted
zones for tilling of genetically modified cotton (Annex of the Ministry of Agriculture and Supply
(MAPA) Directive nº 21/2005) of this event GlyTol x LibertyLink (GTxLL) and other
transformations shall be strictly followed by monitoring bodies, both in the marketing of seeds
in such areas and in technical guidance and monitoring of the interested company. CTNBio,
along the assessment phases of this process, examined the reports submitted by applicant as
well as the independent scientific literature.
TECHNICAL OPINION.
I. Identification of GMO
Name: Genetically modified cotton tolerant to the gluphosinate
ammonium herbicide and to the glyphosate herbicide, named
GlyTol x LibertyLink (GTxLL – event GHB614 X LLCotton25.
Applicant: Bayer S.A.
Species: Gossypium hirsutum L.
Inserted Characteristics: Tolerance to glyphosate and gluphosinate ammonium herbicides
Insertion Method: Classical genetic improvement, by crossing and selection among
individuals containing events GlyTol x LibertyLink (GTxLL)
Proposed use: Production of fibers for the textile industry; and grains for human
and animal consumption, and its derivatives.
II. General Information
Cotton belongs to genus Gossypium, tribe Gossypieae, family Malvaceae, order Malvales
(Fryxell, P.A., 1979; Munro, J.M., 1987).L This genus is further divided into four subgenera
(Gossypium, Sturtia, Houzingenia and Karpas) which, in turn, are divided into nine sections and
several subsections (Fryxell, P.A., Craven, L.A., and Stewart, J.MCD, 1992). The Gossypium
genus is made of 52 species distributed in the Asian, African, Australian and American
continents, of which only 4 are farmed. Especially, three species belonging to such genus are
found in Brazil: Gossypium hirsutum L., var. latifolium; Gossypium hirsutum L. r. marie galante;
Gossypium mustelinum; and Gossypium barbadense (Embrapa, Algodão, 2004). In the
production chain, about 90% of the world cotton population is Gossypium hirsutum L., and 8%
is Gossypium barbadense L. (Lee, 1984).
Brazil is the original center of G. mustelinum and an important center of diversity for G.
barbadense and G. hirsutum r. marie galante. According to Freire et al. (1990), the species G.
mustelinum was never improved nor commercially explored, despite evidences of allele
introgression of G. hirsutum in its genome (Wendell et. al., 1994). Its original center is the
Brazilian Northeast, where there are some populations in the Municipalities of Caicó, RN;
Macurerê, BA; and Caraíba, BA (Freire, 2000).
Two varieties are found in Brazil, both in a semi-domesticated state: Rim-de-Boi (G.
barbadiense var. brasiliense) having linterless seeds, strongly attached to each other,
resembling an ox kidney. The other variety (G. barbadense var. barbadense), known as
Quebradinho or Maranhão, has linterless, detached seeds. This variety comes from the north
of Peru and south of Ecuador, and is likely to have been introduced in Brazil by indigenous
populations, the descendants of which still today use the fibers in handmade fabrics, as a
medicinal plant and oil lamp wicks. Both varieties are arboreal and perennial. They are widely
distributed in Brazil and preserved by farmers for generations. They may be found in the
Amazonian region, in the lowlands of Maranhão and Piauí, in cities of the mining cycle of the
State of Mato Grosso, in the Mato Grosso Marsh surrounding areas and in the Atlantic Forest,
from Rio Grande do Norte to Espírito Santo. Dispersion of the two varieties of G. barbadense in
different locations was due to farming practices (Boulanger & Pinheiro, 1972; Smith & Cothren,
1999).
The species Gossypium hirsutum, also known as herbaceous cotton plant, is largely farmed in
Brazil (Craven et al., 1994) and is the main species cultivated in the world for production of
cotton fiber (Penna, J.C.V., 2005). Cotton tilling in Brazil ranks among the main ten agricultural
cultures in the country, and is the sixth most cultivated plant in the world as far as cultivated
surface is concerned.
III. Description of GMO and Expressed Proteins
The combined event GHB614 x LLCotton25 was obtained by applicant through classical genetic
improvement by crossing GHB614 cotton, genetic background FM958, and LLCotton25, genetic
background FM981. Combined cotton GHB614 x LLCotton25 is the F3 descendant of the
crossing between them and the selection of individuals with the desired features. Both events
have already been separately released by CTNBio through Technical Opinion 1521/2008
(published in the Federal Official Gazette nº 171, of 09.04.2008), regarding commercial release
of genetically modified cotton tolerant to the herbicide gluphosinate ammonium (LibertyLink,
Event LLCotton25, cotton) and Technical Opinion nº 2754 (published in the Federal Official
Gazette nº 241, of12.17.2010), related to the commercial release of genetically modified
cotton tolerant to the herbicide glyphosate (GlyTol, Event GHB614, cotton).
LibertyLink, Event LLCotton25, Cotton
Gene bar, obtained from bacteria Streptomyces hygroscopicus, is expressed in LLCotton25. The
bar gene expresses enzyme PAT (phosphinothricin N-acetyl transferase) that catalyzes the
acetylation reaction of phosphinothricin, producing the inactive compost N-acetil
phosphinothricin, which is later metabolized in the plant cells. The synthetic phosphinothricin
is named gluphosinate ammonium, which controls invading plants for being an inhibitor of the
glutamine synthase enzyme (GS), responsible for incorporating of ammonia to the glutamic
acid, forming the glutamine. GS inhibition results in a deficit of glutamine and accumulation of
ammonia until it reaches toxic levels in the plant cells, leading to desiccation of the plant.
Gluphosinate has a large action spectrum, controlling both dicotyledons and monocotyledons.
Tolerance to the herbicide gluphosinate ammonium is a resulting feature of Cotton event
LLCotton25.
Event LLCotton25 contains the chymeric gene p35S::bar::Nos3’, with one intact copy in the
cassette. The event was obtained through genetic transformation of Coker 312 cotton
mediated by Agrobacterium tumefasciens containing the binary vector pGSV71.
Regarding the PAT protein, when the risk was being analyzed (proceedings nº
01200.001894/2004-01) it became clear that: (i) it has no homology with any allergenic
protein, toxin, or antinutrients; (ii) it has no glycosilation site (present in several allergenic
components); (iii) it is structurally unstable in acid environments; (iv) it degrades and
denatures quickly in the gastric and intestinal fluids of mammals; (v) it has substratum-specific
activity; and (vi) it has no adverse effects in mammals, even when the pure protein is
intravenously administered in high doses. Therefore, there is no evidence that the PAT protein
may cause adverse effects to human and animal health.
GlyTol Cotton, Event GHB614
Gene 2mepsps, originated from corn gene epsps (Zea mayz) changed through a site mutation
directed in two amino acids of the original peptide sequence, altering positions 103 (isoleucin
substituted by threonine) and 107 (serine substituted by proline). Enzyme EPSPS
(5-enolpyruvylshikimate-3-phosphate synthase, E.C. 2.5.1.19) is basic in the pathway
responsible for synthesizing aromatic amino acids in plants and different microorganisms
(Gruys & Sikorski, 1999). Enzyme 2mEPSPS has high similarity with corn EPSPS (>99.5%), yet it
displays lower affinity by the glyphosate molecule (Lebrun et al.), granting GHB614 cotton
selectivity to the herbicide effect of the active ingredient, enabling GHB614 cotton to have
sufficient enzyme activity even under the presence of the glyphosate herbicide.
Event GHB614 contains the chimerical gene
Ph4a748At-intron1h3At-TPotpC::2mepsps::3’histonAt, and there is one intact copy of the
cassette. This event was obtained through genetic transformation of Coker 312 cotton variety,
mediated by Agrobacterium tumefasciens, containing the binary vector pTEM2.
According to a risk analysis performed by CTNBio (proceedings nº 01200.000800/2010-17)
there is no evidence that protein 2mEPSPS may offer risk to human/animal health as against
the use of conventional cotton and its byproducts in food. Protein 2mEPSPS was obtained
from a corn native protein and its safety is shown by studies in animal feeding (birds treated
with cottonseed cake); digestibility analysis of the protein in simulated gastric and intestinal
tracts; tests of acute toxicity through oral and intravenous application; and absence of
homology of the 2mEPSPS with toxic and allergenic compounds.
Individual events LLCotton25 and GHB614 are approved in different countries. Event
LLCotton25 was first approved in the United States in 2003 and is currently approved in eleven
countries. Event GHB614 was first approved for planting in the United States in 2009 and is
currently approved in nine countries (source: http://www.cera-gmc.org;
http://wwwbiotradestatus,com/results.cfm). At this moment, there are ten events combined
in cotton approved in different parts of the world featuring tolerance to herbicides and/or
resistance to insects. Combined cotton GTxLL is approved in Japan, Mexico, Australia, Canada,
and, in the USA, for planting. In Brazil, CTNBio approvals of genetic modification events
granting tolerance to the glyphosate herbicide include four cotton events (GHB614 cotton,
MON1445 cotton, MON531xMON1445 cotton, MON88913 cotton); two soybean events
(GTS-40-3-2 soy, MON87701Xmon89788) and eleven maize events (NK603 maize, GA21 maize,
MON810Xnk603 maize, BT11xGA21 maize, TC150xNK603 maize, BT11xMIRxGA21 maize,
MON89034xNJK603 maize, MON88017 maize, MON89034xNK602 maize,
MON810xTC1507xNK603 maize, and MON89034xMON88017 maize). In case of genetic
modification that grant tolerance to the gluphosinate ammonium herbicide, CTNBio approved,
in addition to LLCotton25: A2704-12 soybean, A5547-127 soybean TG25 corn, BT11 maize and
TC1507 maize.
Considering that the EPSPS acts in the metabolism of aromatic amino acids, more specifically in
the shikimate pathway, in the synthesis of the Chorismate compound and that the PAT enzyme
has no vital function, acting solely in the acetylation of the gluphosinate ammonium herbicide,
there is no indication that such proteins may interact, since they are independent from each
other, there is no competition for substrates, and there is not inhibition by the final product.
IV. Aspects Related to Human and Animal Health
GlyTol x LibertyLink cotton may be classified as Risk Class I (low individual risk and low risk for
the collectivity), since the DNA sequences of donor and receiving organisms cause no harm to
human and animal health nor adverse effects to plants and the environment.
According to the records forwarded by Bayer, one may state that the hypothesis of interaction
between the proteins PAT and 2mEPSPS is practically none, since expression of both proteins
is given through combination by conventional crossing of the parent plants and not by
insertion of recombinant DNA. Besides, the metabolic pathways involving the proteins are
different. This averment is based in tests conducted on GlyTol x LibertyLink cotton and its
genetically modified parents resulted tenors of PAT and 2mEPSPS in leaves, corns and buds
practically identical. Applicant represents that the data obtained show that PAT and 2mEPSPS
proteins do not depend nor are affected by each other presence, fail to compete for substrate
and there is no inhibition by the final product of compounds.
Applicant additionally represents that safety of GlyTol x LibertyLink cotton has already been
shown by the separate events GlyTol and LivbertyLink. Western Blot analyses evidenced that
the protein profile, after cleavage with the same restriction enzymes used in the cleavage of
the parental plants, is not different when compared the stacked effect and the related parents,
leading to the belief that there are no changes in the genetic modification resulting from the
crossing and conventional improvement of the genetically modified parents.
Applicant informs that the insert flank region was maintained after combination of the
genetically modified parents after crossing for classical genetic improvement.
The in-silico analysis, using bioinformatic tolls, was conducted to assess the presence of genes
and open reading frames (ORF) at the junction regions, as well as to assess the presence of
new coding sequences. The results showed presence of two ORFs, but the results of the insilico
analysis for these regions showed that there was no full presence of promoters, therefore
there is no possibility of generating messenger RNA.
For event LLCotton25 (LibertyLink) flank region, determination of the insertion locus of the
insert was possible. It was ascertained, by homology, that the flank regions of the insert LL25
correspond to the sequence existing in the conventional cotton genome (non modified parent).
In-silico analyses were conducted to assess whether there was any functional gene of ORF
change due to the insertion of the bar cassette. The analysis identified a total of twelve
interrupted ORFs and one gene that traverses the deleted region, yet no homology was found
with any protein of the databanks, indicated as very improbable that the gene found may be
expressed in the cotton. Applicant states that all ORFs were analyzed and none displayed
similarity or identity to unwanted sequences.
Cotton use in food chain is limited to animals, which are fed with cottonseed meal and cake.
Only cotton oil extracted from seeds is used for human consumption. This oil is normally
purified, that is to say, becomes exempt from the GMO (DNA, proteins) and other GMO
derivatives. Marketed cotton has antinutritional and toxic factors, such as gossypol,
cyclopenoid fatty acids and phytic acid, which prevent its use as food. With processing, the
level of such elements drops considerably.
Applicant informs that the combination of events GlyTol and LLCotton25 through classical
genetic improvement fails to result in any new product or organism that may threaten
alimentary safety, including safety in the separate events.
Substantial equivalence comparison analyses were conducted between the combined cotton
and its conventional FM958 isoline, both with and without the use of herbicides, and studies
with their parents GlyTol and LibertyLink. According to applicant, the analyses showed that
there is no statistically significant difference between the treatments. The variables in which
significant differences were recorded were due to different localities analyzed, and in some of
the components that are not biologically relevant, since they are within the limits of the
species natural variation.
Toxicologic and pharmacologic assessment studies in animals were conducted when the
requests for commercial release of events GlyTol and LibertyLink were submitted. Similarity
verification studies of products of expression of GlyTol x LibertyLink cotton with known
allergens were submitted for the individual events and, according to applicant, proteins
2mEPSPS and PAT failed to display homology with toxic and allergenic compounds.
V. Environmental Aspects
Genus Gossypium, to which the cotton plant belongs, comprises 52 species out of which only
four are cultivated in the world. Among such species (Gossypium arboretum L., Gossypium
hirsutum L., and Gossypium barbadense L.) production of G. hirsutum represents around 90%
of the cotton marketed all over the world (Lee, 1984).
As mentioned above, Brazil is the original center of some species of the genus Gossypium. G.
barbadense is widely distributed, and its occurrence takes place mainly as a backyard plant,
while G. hirsutum of the marie galante race was largely cultivated in the Northeast during the
seventies and later resumed its wild features after its tillage was abandoned.
According to a risk assessment conducted by the applicant (Freire, 2012), regarding pollen
flow, the rates of transgenic cotton to conventional cotton shall not be different from that
measured in conventional cultivars, since there is no morphological characteristic
differentiating the genetically modified cotton plant from conventional cultivars. Combined
event cotton plants, through classical genetic improvement, failed to originate any new
product or organism able to change the gene flow rate measured for the species.
Regarding sylvan cotton, the likelihood of gene flow with genetically modified cotton is remote
due to the isolation foreseen for commercial planting (distributed in the high technology
cerrado crops) in areas recognizably exempt from sylvan types (Freire, 2000). Though there is
total sexual compatibility between the tetraploid cotton species (G. hirsutum and G.
barbadense), the greater hindrance to crossing between perennial (sylvan) and annual
(cultivated) species is the difference in cycle and lack of coincidence in flowering periods. In
case gene flow does take place, it fails to affect the genome of the receiving plant, since the
alleles received by cross fecundation are inserted solely in the progeny (that is to say, in seeds
that are harvested with the lint cotton) and there will be no adaptive advantage against other
varieties, since farming practices of the sylvan cotton include hand weeding, with cultivation of
small areas.
Applicant additionally argues that the change in the distribution pattern of sylvan varieties in a
given environment, following a genetic transfer, shall be analyzed considering several features
that may be incorporated. Many features that are present in modern varieties of conventional
cotton, such as resistance to diseases, high productivity and production of fructiferous
branches, may favor adaptive ability and survival of sylvan species and lead to their widespread
in some regions, since the selection factor does not depend from a man controllable factor.
Regarding characteristics of selectivity to herbicides, these shall not be seen as fundamental
selection factors enabling adaptive advantages of the genetically modified variety as against
other varieties. Regarding the crossing with weed, under Brazilian conditions the regions
cultivated with cotton fail to exhibit any weed that may be sexually compatible with the
cultivated Gossypium species.
Considering the studies conducted in planned releases, they showed that the presence of bar
and 2mepsps genes in cotton GTxLL failed to change in a significant amount any phenotypic
characteristic, related to phonological studies during the cycle or the growth parameters and,
considering in addition the literature data on gene flow and gene introgression in cotton
plants, there is no evidence that any characteristic could make the GM cotton to be more
invasive than the conventional cotton lineages.
Southern blot analyzes showed that there is the same band standard in the combined cotton
GTxLL and the individual events GHB614 and LLCotton25. Analyzes conducted showed that the
structure of the insert, its location and stability were not changed by the combination. Both
sizes and numbers of fragments observed in DNA hybridation analyzes corresponded to the
expected results (Moens, 2010).
Expression of proteins 2mEPSPS and PAT in leaves, seeds (corn) and flower buds in cotton
GTxLL was assessed against their parents. The plants were greenhouse cultivated and the
material was collected, and proteins PAT and 2mEPSPS extracted and quantified by ELISA
(Thompson, 2009). Considering that the analysis conducted revealed difference in the
expression of proteins in the combined event when contrasted with the parental line, a review
was requested for analysis and criticism of potential biosafety risks, considering that
assessment of the proteins expression was a study intended to show inexistence of interaction
between the proteins expressed in the combined event. Answering to the request, applicant
offered the following arguments:
• Variations in gene expression and consequently in content of expressed proteins are
highly dependent of several factors such as age and sanity of the tissue examined, and
environmental conditions such as (temperature, radiation, humidity) (Floris et. al,
2009);
• Potential expression level differences may be expected between combined and
individual events, since it also happens in conventional crossings between non-GM, as
a consequence of the difference in germplasm (genetic background). By the same
token, expression of transgenes may also change when inserted in different genetic
backgrounds (EFSA, 2007; De Schrijver et. al., 2007). GTxLL cotton stems from genetic
crossing between varieties FM958 and FM981, that have different genetic bases that,
consequently may explain a possible change in the expression pattern of proteins
2mEPSPS and PAT when compared with the parents;
• The hypothesis of interaction between the inserts may not be analyzed based on a
sole parameter. This analysis shall be conducted in a wider way, taking other data into
consideration, such as phenotypic analyses;
• In another study performed by applicant for quantification of protein 2mEPSPS in
flower tissues of different ages (Robinson, 2011), the results showed large
superposition in amplitude of measured values, comparing GTxLL cotton and its
parents.
Applicant submitted the result of a study conducted in the cities of Santo Antonio do Leste,
State of Mato Grosso and São Desidério, State of Bahia (Freire, 2012) were no statistic
differences were recorded between phenologic, morphologic characteristics, and production
components between the non modified cotton plant and individual events GlyTol and
LibertyLink and the combined event GTxLL. The parameters assessed indicate that the
combination of individual events, by crossing and selection, was unable to change gene
specificity and failed to exhibit both pleiotropic and epistatic effects.
Humidity, gross protein, lipids, ashes, carbohydrates, fiber, minerals, vitamins and
antinutrients parameters were studied, comparing samples of GTxLL cotton with the non
modified parent. When comparing data of cotton GTxLL with the parents GHB614 and
LLCotton25, the results showed some differences between averages for the compounds such
as ashes, calcium, α-tocopherol, free gossypol, total gossypol, phytic acid, dihydro-sterculic
acid, and potassium. Estimated average differences are within the variation range for the
commercial cotton varieties described in the literature (OECD, 2004); ILSI Crop Composition
database).
VI. Restrictions to the Use of the GMO and Derivatives
Analysis of alimentary and environmental biosafety of cotton Glytol x LibertyLink (GTxLL),
event GHB614 x LLCotton25 showed that this cotton is equivalent to conventional cotton and
commercial references. Besides, there is no evidence of adverse reactions related to the use of
GlyTol x LibertyLink (GTxLL), event GHB614 x LLCotton25. Therefore, there are no restrictions
to the use of this cotton or any of its derivatives for both human and animal consumption.
VII. Considerations on Particulars of Different Regions of the Country (information to
monitoring bodies)
Zones where farming of this genetically modified cotton, GlyTol x LibertyLink) GTxLL event
GHB614 x LLCotton25 and other transformations are restricted (Annex to the Ministry of
Agriculture Directive nº 21/2005) shall be rigorously observed by monitoring bodies, both
regarding the trade of seeds in such areas and technical guidance and monitoring of the
applicant.
VIII. Conclusion
Whereas:
• Cotton (Gossypium hirsutum) variety event GHB614 x LLCotton25 belongs to a well
characterized species with a solid history of safety for human consumption;
• Proteins PAT and 2mEPSPS granting tolerance to the herbicide gluphosinate
ammonium and glyphosate, respectively, are expressed in several events of different
agricultural cultures already submitted to risk assessment and approved for
commercial use in numerous countries;
• Parents, event GHB614 and LLCotton25, were submitted to risk assessment by CTNBio
and were granted a favorable opinion for their commercial release;
CTNBio reached the conclusion, expressed by the majority of its members, that this activity is
not potentially a cause of significant degradation of the environment nor harmful to human
and animal health. Restrictions to the use of this GMO and its derivatives are mentioned in the
provisions of the Ministry of Agriculture Directive nº 21/05.
In the context of the competences vested in it by Article 14 of Law nº 11105/2005, CTNBio
finds that the request is under current regulations and legislation in effect, aiming and securing
environmental, agricultural, human and animal health biosafety, and concluded that cotton
GlyTol x LibertyLink (GTxLL) event GHB614 x LLCotton25 is substantially equivalent to
conventional cotton and that its consume is safe for human and animal health. Regarding the
environment, CTNBio concluded that cotton GlyTol x LibertyLink (GTxLL) event
GHB614 x LLCotton25 is not potentially a cause of significant degradation of 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
instructions be followed and technical monitoring actions be conducted as mentioned by
CTNBio Ruling Resolution nº 09, of December 02, 2011.
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