substantial equivalence copy

Barbara H. Peterson

Farm Wars

For years we have been told that genetically engineered crops (GMOs) are “substantially equivalent” to their non-engineered counterparts. But what does that mean?

The term substantial equivalence was first mentioned in connection with food safety in a report of the OECD Group of National Experts on Safety in Biotechnology (OECD, 1993). The members of the group agreed that the most practical approach to determining the safety of foods derived by modern biotechnology is to consider whether they represent a substantial equivalent to analogous traditional products. The term substantial equivalence and the underlying approach were “borrowed from the US Food and Drug Administration’s (FDA) definition of a class of new medical devices that do not differ materially from their predecessors and thus, do not raise new regulatory concerns” (Miller, 1999).

In other words, not different enough to warrant concern. So, if GMOs are substantially equivalent to their natural counterparts, this means that they are basically the same in every respect, except of course, for that minor detail of having been manufactured in a laboratory, genetically engineered with viruses, bacteria and genes from species that would never combine in the natural world, and are engineered to be resistant to pesticides and/or to kill bugs with one bite. But not to worry, they are substantially equivalent. Or are they?

A Brazilian study has found unintended differences in proteins between a GM maize and the non-GM parent variety

Comparison of the GM and non-GM plants revealed a total of 32 different proteins that were differentially expressed. The proteins were either present, absent, up- or down-regulated in one of the hybrids, at a statistically significant level…

The ‘substantial equivalence theory’ regulatory “method is rather vague and does not specify the level of similarity between the chemical composition of plants that allow them to be considered “equivalent”, but it still secured the release of GMOs in the USA and other countries and is still used today (including by CTNBio – National Technical Biosafety Commission) to justify not carrying out in-depth studies to assess risks of the new plants.

Not so equivalent after all, eh? What would happen if we applied the same reasoning to other living beings that biotech and the US government apply to GMO crops?

An international team of researchers has sequenced the genome of the bonobo for the first time, confirming that it shares the same percentage of its DNA with us as chimps do. The team also found some small but tantalizing differences in the genomes of the three species—differences that may explain how bonobos and chimpanzees don’t look or act like us even though we share about 99% of our DNA.

It appears that we share about 99% of our DNA with the bonobo chimp. The difference is in the way the genes are expressed.

Gene expression differences

According to Oldham et al., a major genome paradigm is now recognized for which

“ … the high extent of sequence homology between human and chimpanzee proteins supports the longstanding hypothesis that many phenotypic differences between the species reflect differences in the regulation of gene expression, in addition to differences in amino acid sequences.”32

In fact, as early as 1975 King and Wilson postulated that the major differences between humans and apes were due largely to factors controlling gene expression:

“We suggest that evolutionary changes in anatomy and way of life are more often based on changes in the mechanisms controlling the expression of genes than on sequence changes in proteins. We therefore propose that regulatory mutations account for the major biological differences between humans and chimpanzees.”33

The only logical conclusion that one can come to when trying to determine the reasoning behind biotech’s “substantial equivalence” doctrine is that gene expression is not a consideration. If gene expression is not a consideration, then there is nothing to separate man from ape, and the CEO of Monsanto is substantially equivalent to our furry friend, the bonobo chimp.

©2014 Barbara H. Peterson

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7 Responses to “Substantial Equivalence Monsanto Style”

  1. Emmett Grogan says:

    B. Talbert: Sorry, no, it wasn’t a bonobo, it was a regular chimpanzee, I remember the story. The only time any bonobo got violent was in captivity when moms were separated from sons and even then they didn’t attack humans. There are few bonobos, if any at this time, in captivity. Google: bonobo chimp mauls woman’s face and you won’t find anything but google “chimp mauls woman’s face” and you’ll find it was a chimpanzee, who are notoriously aggressive and violent. This is my point is that the 2 are very, very different in their behaviors.
    Franz de Waals has studied chimpanzees and bonobos his entire adult life and he’s no spring chicken. Read his book “Our Inner Ape”. I think Il’l go with his opinions, as he’s studied this in depth and is a professor of psychology at Emory University. Respectfully, I doubt you have anywhere near his credentials and expertise.

  2. B. Talbert says:

    I believe the poor lady who had her face mauled by a Bonobo chimp would differ with your opinion. “Wild”animals are unpredictable. They have some obligate behaviors and some unpredictable others. The lower orders of life have more obligate behaviors so that they keep their place in the order of things plan. Man is distinct with conscious free will.
    Of course the assignment of genetically altered foods to a designation of substantially equivalent is just plain wrong. Common sense tells us that but common sense has taken leave of our senses, swept and scoured out of there by lies and obfuscations and the desire to sell things and be “funded”.

  3. Sued by a chimp for defamation of character ;)

  4. Even the most furious chimpanzee would feel it’s character was defamed. By being associated with Hugh Grant CEO of Monsanto makes the worst chimp look like a saint in comparison.

  5. abinico warez says:

    Trivalent chromium is substantially equivalent to hexavalent chromium. The former is a needed nutrient; the latter is a deadly toxin, yet the difference is 3 tiny-weeny, itsy-bitsy electrons. So the GMO argument of substantial equivalence is meaningless – GMO can be deadly compared to natural food even though they are ‘substantially equivalent’.

  6. I stand corrected, Emmett. The “Common Chimpanzee” is more accurate ;)

  7. Emmett Grogan says:

    Barbara: I appreciate the point you are making but I have to disagree that the CEO of Monsanto is in any way similar to the bonobo. Humans also share 99% DNA with chimpanzees as well as the bonobo yet the 2 are very different. Chimpanzees are given to erratic emotions and will attack at a moment’s notice. They are known to be cruel in the extreme. Bonobos, OTOH, are peaceful and violence is unknown among them. When a male bonobo starts to get rough with one of the kids, the females will jump him and initiate sex with the male to calm him down. No one gets hurt and everyone ends up happy. The peacefulness of the bonobo is legendary and unfortunately, is what is contributing to their demise. Franz de Wall writes about this in several books and says that basically humans have 2 choices: we can become aggressive violent like the chimp or we can become peaceful and loving, like the bonobo – which one is humanity going to choose? Monsanto is anything but peaceful and loving. They are far more like the chimps.