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The Norwegian Environment Agency (NEA) and the Norwegian Food Safety Authority (NFSA) requested the Norwegian Scientific Committee for Food Safety (Vitenskapskomiteen for mattrygghet, VKM) for an opinion of potential risks to biodiversity and agriculture in Norway Grey Literature Meadow et al.; EJNFS, 8(2): 100-104, 2018; Article no.EJNFS.2018.010 101 associated with import of seeds for sowing and cultivation of insect-resistant and herbicide tolerant genetically modified maize Bt11 under Directive 2001/18/EC (Notification C/F/96.05.10). The notification is still pending for authorisation in the European Union. VKM is also requested to assess the applicant ́s post-market environmental monitoring plan, and the management measures suggested in the draft implementing decision of the European Commission. As the scope of the notification does not cover food and feed uses of maize Bt11, VKM was not asked for a health risk assessment of maize Bt11. However, VKM has decided to update a previous safety evaluation of the food and feed uses of maize Bt11 and derived products (VKM, 2014). VKM appointed a working group consisting of members from the Panel on Genetically Modified Organisms, the Panel on Alien Organisms and trade in Endangered Species (CITES) and the VKM staff to answer the requests. The Panel on Genetically Modified Organisms assessed and approved the final report. The genetically modified maize Bt11 was developed to provide protection against certain lepidopteran target pests, such as the European corn borer (ECB, Ostrinia nubilalis), and some species belonging to the genus Sesamia . The insect resistence is achieved by the expression of a truncated form of a Cry1Ab protein encoded by a modified cry1Ab gene derived from the soil microorganism Bacillus thuringiensis subsp kurstaki HD-1. Maize Bt11 also expresses the phosphinothricin N ace tyltransferase (pat) gene, derived from the soil microorganism Streptomyces viridochromogenes strain Tu494, which encodes the enzyme: phosphinothricin acetyl transferase (PAT). PAT protein confers tolerance to the herbicidal active substance glufosinate-ammonium. The PAT protein expressed in Bt11 was used as a selectable marker to facilitate the selection process of transformed plant cells and is not intended for weed management purposes. Since the scope of the notification C/F/96.05.10 does not cover the use of glufosinate-ammonium-containing herbicides on maize Bt11, potential effects due to the use of such herbicides on maize Bt11 are not considered by VKM. In delivering its scientific opinion, VKM considered relevant peer-reviewed scientific publications and information provided by the applicant in the notification C/F/96.05.10, the renewal application EFSA/GMO/RX/Bt11, and scientific opinions and comments from EFSA and other EU-member states. VKM has evaluated maize Bt11 with reference to its intended uses in the European Economic Area (EEA), and according to the principles described in the Norwegian Food Act, the Norwegian Gene Technology Act and regulations relating to impact assessment pursuant to the Gene Technology Act, Directive 2001/18/EC on the deliberate release into the environment of genetically modified organisms, and Regulation (EC) No 1829/2003 on genetically modified food and feed. The Norwegian Scientific Committee for Food Safety has also decided to take account of the appropriate principles described in the EFSA guidelines for the risk assessment of GM plants and derived food and feed (EFSA 2011a), the environmental risk assessment of GM plants (EFSA 2010a), selection of comparators for the risk assessment of GM plants (EFSA, 2011b) and for the post-market environmental monitoring of GM plants (EFSA, 2011c). The scientific risk assessment of maize Bt11 includes molecular characterisation of the inserted DNA and expression of novel proteins, comparative assessment of agronomic and phenotypic characteristics, nutritional assessments, toxicology and allergenicity. An evaluation of unintended effects on plant fitness, potential for gene transfer, interactions between the GM plant and target and non-target organisms, effects on biogeochemical processes, the post-market environmental monitoring plan and coexistence measures at the farm level has also been undertaken. It is emphasised that the VKM mandate does not include assessments of contribution to sustainable development, societal utility and ethical considerations, according to the Norwegian Meadow et al.; EJNFS, 8(2): 100-104, 2018; Article no.EJNFS.2018.010 102 Gene Technology Act and Regulations relating to impact assessment pursuant to the Gene Technology Act. These considerations are therefore not part of the risk assessment provided by the VKM. Molecular Characterization: Appropriate analyses of the integration site, inserted DNA sequence, flanking regions, and bioinformatics have been performed. The molecular characterisation reported by the applicant shows that the DNA-fragment containing the cry1Ab and pat genes, is integrated as a single copy at a single locus in the nuclear genome of maize Bt11 and that it is stably inherited as a dominant trait. VKM considers the molecular characterisation of maize Bt11 satisfactory. Comparative Assessment: Comparative analyses of data from field trials located at representative sites and environments in North America and Europe indicates that maize Bt11 is compositionally equivalent to its conventional counterpart, with the exception of the herbicide tolerance and insect resistance traits, conferred by the expression of the PAT and Cry1Ab proteins. However, data on the amino acid tryptophan, is only given in one out of six studies. Based on current knowledge, VKM concludes that maize Bt11 is compositionally equivalent to conventional maize. The data provided by the applicant are not sufficient to show that Bt11 maize is phenotypically and agronomically equivalent to conventional near-isogenic maize lines. The agronomic assessment data are provided from one growing season in the North America and one growing season in France. This is not considered to be sufficient for representative testing of agricultural environments. Food and Feed Risk Assessment: Whole food feeding studies have not indicated any adverse health effects of maize Bt11. These studies further support that maize Bt11 is nutritionally equivalent to conventional maize. The Cry1Ab and PAT proteins do not show sequence resemblance to other known toxins or IgE allergens, nor have they been reported to cause IgE mediated allergic reactions. Some studies have however indicated a potential role of Cry-proteins as adjuvants in allergic reactions. Based on current knowledge, the VKM concludes that maize Bt11 is nutritionally equivalent to conventional maize varieties. It is unlikely that the Cry1Ab and PAT proteins will introduce a toxic or allergenic potential in food or feed based on maize Bt11 compared to conventional maize. Environmental Risk Assessment: Maize is the only representative of the genus Zea in Europe, and there are no cross-compatible wild or weedy relatives outside cultivated maize with which maize can hybridise and form backcross progeny. Vertical gene transfer in maize therefore depends on cross-pollination with other conventional or organic maize varieties. In addition, unintended admixture of genetically modified material in seeds represents a possible way for gene flow between different crop cultivations. The risk of pollen flow from maize volunteers is negligible under Norwegian growing conditions. Since maize Bt11 has no altered agronomic and phenotypic characteristics, except for the specific target insect resistance and herbicide tolerance, the likelihood of unintended environmental effects as a consequence of spread of genes from maize Bt11 is considered to be extremely low. There are no reports of the target lepidopteran species attaining pest status on maize in Norway. Since there are no Bt-based insecticides approved for use in Norway, and lepidopteran pests have not been registered in maize, issues related to resistance evolution in target pests are not relevant at present for Norwegian agriculture. Published scientific studies showed that the likelihood of negative effects of Cry1Ab protein on non-target arthropods that live on or in the vicinity of maize plants is low. Meadow et al.; EJNFS, 8(2): 100-104, 2018; Article no.EJNFS.2018.010 103 In Norway, the maize cultivation is marginal. The total crop area of forage maize is estimated to 2000-2800 decares, equivalent to less than 0.1% of the areas with cereal crops. The area of individual fields is limited by the topography such that the quantity of maize pollen produced under flowering is also limited. The potential exposure of Cry1Ab-containing maize pollen on non-target lepidopteran species in Norway is therefore negligible. Cultivation of maize Bt11 is not considered to represent a threat to the prevalence of red-listed species in Norway. Exposure of nontarget organisms to Cry proteins in aquatic ecosystems is likely to be very low, and potential exposure of Cry proteins to non-target organisms in aquatic ecosystems in Norway is considered to be negligible. VKM concludes that, although the data on the fate of the Cry1Ab protein and its potential interactions in soil are limited, the relevant scientific publications analysing the Cry1Ab protein, together with the relatively broad knowledge about the environmental fate of other Cry1 proteins, do not indicate significant direct effects on the soil environment. Despite limited number of studies, most studies conclude that effects on soil microorganisms and microbial communities are transient and minor compared to effects caused by agronomic and environmental factors. However, data are only available from short-term experiments and predictions of potential long-term effects are difficult to deduce.

european journal of nutrition and food safety

Risk Assessment of Insect-resistant and Herbicide Tolerant Genetically Modified Maize Bt11 for Cultivation, Import, Processing, Food and Feed Uses under Directive 2001/18/EC and Regulation (EC) Opinion