Comments Submitted to the USMCA Genetically Engineered Corn Dispute Resolution Tribunal

Intensification of Industrial GE Corn Production The scope of GE-corn human health risk assessments have failed to evolve in step with the intensification of industrial corn production, and in particular, changes in the mix of Bt/VIP toxins and herbicide-tolerant traits in specific cultivars. [...] S., the scope and adequacy of scientific research and regulatory oversight of GE-corn human health impacts has receded in the wake of persistent political pressure for “regulatory relief”.8 Presence of Bt Endotoxins and Herbicide Residues in Corn 8 For example, the U. [...] National Academy of Sciences has also noted the need for more rigorous food safety assessments of stacked varieties and has called for making compositional and expression data on all GE cultivars public.13 Unfortunately, the testing and food safety assessments called for in the 2000s by the FAO/WHO, NAS, and the EPA’s Scientific Advisory Panel have not been acted upon in the case of any highexpres. [...] The antimicrobial activity of GLY disrupts the bacterial microbiome in humans and other mammals, while Bt endotoxins can damage the lining and functionality of the stomach and intestines.14 A study in mice found that the Cry1Ac protoxin binds to the mucosal surface (brush border membrane vesicles) of the small intestines, thereby possibly affecting its electrophysiological properties and permeabil. [...] This study identified changes that “reduce motor and secretory activity of the GI tract or cause changes in the blood flow as a result of a relaxing effect on the muscular layer of blood vessels.” Conclusions Since the commercial introduction of GE corn in 1996 and event-specific approvals in the 1990s and 2000s, dramatic changes have occurred in corn production systems.