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Presentation to the Monsanto Tribunalby Claire Robinson, editor, GMWatchThis presentation focuses on Monsanto’s history of involvementin dishonest, deceptive, and non-transparent efforts to controlthe scientific and public discourse on genetically modified (GM)foods and crops (and associated pesticides), and to force itsproducts into countries across the globe. It addresses thequestions of whether Monsanto has violated the right to healthand a healthy environment, and has damaged freedom ofexpression and of academic research.Monsanto and other GMO developer companies design regulatorysystems for GMOs1Monsanto and other agricultural biotechnology and chemical companieshave heavily influenced the regulatory system by which geneticallymodified organisms (GMOs) are evaluated for safety in various countriesacross the globe. They have done this through the International LifeSciences Institute (ILSI), a lobby group that works in the arena ofregulatory science and is funded by companies including Monsanto,Bayer, Dow, and Syngenta.2The full story is as follows.Worldwide, regulators approve GM crops and foods as safe based onthe concept of “substantial equivalence”. Substantial equivalenceassumes that if a GMO contains similar amounts of a few basiccomponents such as protein, fat, and carbohydrate as its non-GM1ndThis section is adapted from Fagan J, Antoniou M and Robinson C. GMO Myths and Truths, 2edition. Earth Open Source, 2014. tly-tested-regulated-safety/2Sourcewatch. 2016. http://www.sourcewatch.org/index.php/International Life Sciences Institute

counterpart, then the GMO is substantially equivalent to the non-GMOand no rigorous safety testing is required.The concept of substantial equivalence as applied to GMOs was first putforward by the industry and the Organization for Economic Cooperationand Development (OECD), a body dedicated not to protecting publichealth but to facilitating international trade.3 4Claims of substantial equivalence for GM foods have been widelycriticized and revealed as scientifically inaccurate by independentresearchers5 6 7 8 and by the Royal Society of Canada.9 A useful analogyto help us understand what is meant by substantial equivalence is that ofa BSE-infected cow and a healthy cow. They are substantially equivalentto one another, in that their chemical composition is the same. The onlydifference is in the shape of a protein (prion) that constitutes a minuteproportion of the total mass of the cow. This difference that would not bepicked up by current substantial equivalence assessments. Yet fewwould claim that eating a BSE-infected cow is as safe as eating a healthycow.In reality, when GM foods and crops and their non-GM ‘parents’ areanalyzed and compared, frequently unintended and unexpecteddifferences are found.10Europe has controversially adopted the concept of substantialequivalence in its GM food assessments – but under another name. TheEuropean Food Safety Authority (EFSA) does not use the discredited3Organisation for Economic Cooperation and Development (OECD). Safety evaluation of foodsderived by modern biotechnology: Concepts and principles. OECD Publishing; cepts and Principles 1993.pdf.4Then C, Bauer-Panskus A. European Food Safety Authority: A playing field for the biotech industry.Testbiotech; 2010. http://www.testbiotech.de/en/node/431.5Pusztai A, Bardocz S, Ewen SWB. Genetically modified foods: Potential human health effects. In:D’Mello JPF, ed. Food Safety: Contaminants and Toxins. Wallingford, Oxon: CABI Publishing;2003:347–372. ztai/0851996078Ch16.pdf.6Nodari RO, Guerra MP. Implications of transgenics for environmental and agricultural sustainability.Hist Cienc Saude Manguinhos. 2000;7(2):481-91.7Zdunczyk Z. In vivo experiments on the safety evaluation of GM components of feeds and foods. JAnim Feed Sci. 2001;10:195-210.8Zolla L, Rinalducci S, Antonioli P, Righetti PG. Proteomics as a complementary tool for identifyingunintended side effects occurring in transgenic maize seeds as a result of genetic modifications. JProteome Res. 2008;7:1850-61. doi:10.1021/pr0705082.9Royal Society of Canada. Elements of precaution: Recommendations for the regulation of foodbiotechnology in Canada. An expert panel report on the future of food biotechnology. 2001.http://www.rsc.ca//files/publications/expert panels/foodbiotechnology/GMreportEN.pdf.10For a small selection of references, see “The sham of substantial equivalence” in GMO Myths andTruths: tly-tested-regulated-safety/Presentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 20162

term “substantial equivalence” but has allowed industry to replace it withanother term with the same meaning: “comparative assessment” or“comparative safety assessment”.The story of how the comparative safety assessment made its way intoEurope’s GMO regulatory system is a tale of revolving doors andconflicts of interest with industry.The change of name from “substantial equivalence” to “comparativesafety assessment” was suggested in a 2003 paper on risk assessmentof GM plants.11 The paper was co-authored by Harry Kuiper, then chairof EFSA’s GMO Panel, with Esther Kok. In 2010 Kok joined EFSA as anexpert on GMO risk assessment.12 In their 2003 paper, Kuiper and Kokfreely admitted that the concept of substantial equivalence remainedunchanged and that the name change was in part meant to deflect the“controversy” that had grown up around the term.13At the same time that Kuiper and Kok published their 2003 paper, theywere part of a task force of the GMO industry-funded International LifeSciences Institute (ILSI), that was working on re-designing GMO riskassessment.14 In 2004 Kuiper and Kok co-authored an ILSI paper on therisk assessment of GM foods, which defines comparative safetyassessment. The other co-authors include representatives from GM cropcompanies that sponsor ILSI, including Monsanto, Bayer, Dow, andSyngenta.15EFSA has followed ILSI’s suggestion of treating the comparative safetyassessment as the basis for GM safety assessments. EFSA haspromoted the concept in its guidance documents on assessment ofenvironmental risks of GM plants16 and of risks posed by food and feed11Kok EJ, Kuiper HA. Comparative safety assessment for biotech crops. Trends Biotechnol.2003;21:439–444.12European Food Safety Authority (EFSA). Annual declaration of interests – Esther Kok. 2010.13Kok EJ, Kuiper HA. Comparative safety assessment for biotech crops. Trends Biotechnol.2003;21:439–444.14Then C, Bauer-Panskus A. European Food Safety Authority: A playing field for the biotech industry.Testbiotech; 2010. Available at: nal Life Sciences Institute (ILSI). Nutritional and safety assessments of foods and feedsnutritionally improved through biotechnology, prepared by a task force of the ILSI International FoodBiotechnology Committee. Compr Rev Food Sci Food Saf. 2004;3:38–104.16European Food Safety Authority (EFSA) GMO Panel. Guidance on the environmental riskassessment of genetically modified plants. EFSA J. 2010;8:1879–1990. doi:10.2903/j.efsa.2010.1879.Presentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 20163

derived from GM animals,17 as well as in a peer-reviewed paper on thesafety assessment of GM plants, food and feed.18In 2013 the EU Commission incorporated the industry- and EFSAgenerated concept of the comparative safety assessment into its newregulation on GM food and feed.19There is nothing wrong with beginning a safety assessment with acomparative assessment, as long as this is followed by further rigorouscomparative tests on the GMO and its non-GMO parent, such as –omicsanalyses (to measure protein content, metabolites and gene expression)and long-term animal feeding trials.But a major problem with the comparative safety assessment is that, asthe name suggests, regulatory and advisory authorities are beginning totreat it as a safety assessment in itself, rather than as just the first in aseries of mandatory steps in the assessment process. In other words,EFSA and the EU Commission are moving towards a scenario in which ifthe GMO passes this weak test – and many have, in spite of havingsignificant differences from the non-GM comparators – then they are notsubjected to further rigorous testing.Allowing GMO developer companies to design regulatory procedures fortheir own products is equivalent to allowing a student to write his ownexamination paper.Monsanto pressures US EPA to defend glyphosateFaced with lawsuits brought by people who believe they have beenmade ill by glyphosate herbicides and the reluctance of EU memberstates to re-approve glyphosate, Monsanto has been pulling out all stopsto defend these products. That includes pressuring the US regulator todeclare glyphosate safe.17European Food Safety Authority (EFSA). Guidance on the risk assessment of food and feed fromgenetically modified animals and on animal health and welfare aspects. EFSA J. 2012;10:2501. [43pp.].18European Food Safety Authority (EFSA) GMO Panel Working Group on Animal Feeding Trials.Safety and nutritional assessment of GM plants and derived food and feed: The role of animal feedingtrials. Food Chem Toxicol. 2008;46:S2-70. doi:10.1016/j.fct.2008.02.008.19European Parliament and Council. Commission implementing regulation (EU) no. 503/2013 of 3April 2013 on applications for authorisation of genetically modified food and feed in accordance withRegulation (EC) No 1829/2003 of the European Parliament and of the Council and amendingCommission Regulations (EC) No 641/2004 and (EC) No 1981/2006. Off J Eur Union. 2013. ri OJ:L:2013:157:0001:0048:EN:PDF.Presentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 20164

Veteran agricultural journalist Carey Gillam wrote, “The pressure on theEPA to defend glyphosate began immediately after the World HealthOrganization’s International Agency for Research on Cancer (IARC)declared in March 2015 that research showed glyphosate was ‘probably’carcinogenic to humans. The IARC decision was announced on Friday,March 20, 2015 and by the following Monday morning, Monsanto’s DanJenkins, the company’s regulatory affairs leader, was already calling andemailing EPA officials demanding they “correct” the record on glyphosate.Emails obtained through Freedom of Information request show Jenkinssubmitted ‘talking points’ to the EPA to try to contradict IARC. And sincethen Monsanto has only intensified its efforts to invalidate the findings ofthe IARC group, attacking the veteran scientists as an “unelected,undemocratic, unaccountable and foreign body.”20Thus far Monsanto seems to be getting its wish. In a September 12report, the EPA offered an evaluation of glyphosate’s cancer-causingpotential that ended with a “proposed” conclusion that glyphosate was‘“not likely to be carcinogenic to humans’ at doses relevant to humanhealth risk assessment.”21 However, the EPA will be holding moremeetings in October to discuss the topic further.Roundup and birth defectsIn 2011 a group of scientists, collaborating with me as the main writer,published a report called “Roundup and birth defects”.22 A peer-reviewedversion was published the following year in the Journal of Environmentaland Analytical Toxicology.23Based on an examination of the summaries of industry data andregulatory documents collected by the German government in support ofthe 2002 European approval of the ‘active ingredient’ glyphosate, theauthors found that:20Gillam C. Upcoming EPA meetings on safety of Monsanto weed killer drawing Scrutiny. HuffingtonPost, 29 Sept 2016. g-epa-meetingson b 12245584.html21US EPA. Glyphosate Issue Paper: Evaluation of Carcinogenic Potential. EPA’s Office of PesticidePrograms, September 12, 2016. documents/glyphosate issue paper evaluation of carcincogenic potential.pdf22Antoniou M et al. Roundup and birth defects: Is the public being kept in the dark? Earth OpenSource, 2011. http://bit.ly/2dDdfHP23Antoniou M et al. Teratogenic effects of glyphosate-based herbicides: Divergence of regulatorydecisions from scientific evidence. Journal of Environmental and Analytical Toxicology 2012, S:4.Presentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 20165

Industry (including Monsanto) has known since the 1980s and1990s that glyphosate causes malformations in experimentalanimals at the doses employed in its studies. The German government has known since at least 1998 thatglyphosate causes malformations. The EU Commission has known since at least 2002 thatglyphosate causes malformations. This was the year its DGSANCO division published its final review report, laying out thebasis for the 2002 approval of glyphosate. The public, in contrast, has been kept in the dark by industry andregulators about the ability of glyphosate and Roundup to causemalformations. In addition, the work of independent scientists whohave drawn attention to the herbicide’s teratogenic effects hasbeen ignored, denigrated, or dismissed. These actions on the partof industry and regulators have endangered public health. Based on an objective examination of the industry data summaries,the acceptable daily intake (ADI) for glyphosate should have beenset at one-third of the current level of 0.3 mg/kg bw/d – in otherwords, it should have been set at 0.1 mg/kg bw/d. Taking independent, non-industry animal studies intoconsideration, which were performed with the completeformulations as sold and used rather than just the isolated ‘activeingredient’ glyphosate, the ADI should have been set at least 12times lower, at 0.025 mg/kg bw/d.Of course, no one is exposed to the unrealistically high doses that aretested in industry studies. Also, few people are exposed to glyphosatealone – most people are exposed to the complete herbicide formulations,which are more toxic. So these studies alone do not prove that the dosesof glyphosate herbicide that we are actually exposed to causemalformations.However, there are three important responses to that valid point:1. Modern science recognizes that very low, environmentally relevantdoses of some chemicals can have a more toxic effect than higherdoses – these chemicals are known as endocrine disruptors.24These very low doses of herbicides and pesticides have neverbeen tested for regulatory purposes over a long-term exposureperiod. So we cannot assume that low doses are safe, although24Vandenberg LN et al. Hormones and endocrine-disrupting chemicals:Low-dose effects and nonmonotonic dose responses. Endocrine Reviews, June 2012, /22419778Presentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 20166

current regulatory science does wrongly assume that.2. There are many reports from South America of high rates of birthdefects and cancers in people living in regions close to fields whereGM soy is sprayed with Roundup herbicide and other chemicals.2526This suggests that realistic doses of glyphosate herbicides,either alone or in combination with other chemicals, do haveserious health effects.3. The European pesticides regulation27 has a ‘hazard cut-off’provision for reproductive toxicity. This means that if apesticide/herbicide shows reproductive toxicity in the industry tests,which use high doses, it is not legally allowable to argue that thedoses people are actually exposed to are safe. The pesticide mustsimply be banned.Given the reluctance of regulators to act on indications of glyphosateherbicides’ toxicity, it is urgent that realistic doses of the completeformulations are tested in long-term animal studies by independentscientists.Monsanto and the US government use bullying and illicit tactics topressure other countries to accept GMOsWhile Monsanto positions itself as a science-based company, its way ofgetting its products accepted in countries across the globe often oweslittle to science and much to bullying and illicit tactics.“Causing pain” to countries that don’t want GM crops: In 2011diplomatic cables disclosed by Wikileaks showed that the USgovernment represents Monsanto’s interests by pushing other countriesto adopt GM crops.25Lopez SL et al. Pesticides used in South American GMO-based agriculture: A review of their effectson humans and animal models. In: Fishbein JC and Heilman JM (eds): Advances in MolecularToxicology Vol 6. New York: Elsevier, 2012:41–75.26Comision Provincial de Investigación de Contaminantes del Agua. Primer informe [first report].Resistencia, Chaco, Argentina, April 2010.http://www.gmwatch.org/files/Chaco Government Report Spanish.pdf ; English translation athttp://www.gmwatch.org/files/Chaco Government Report English.pdf27Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 October 2009concerning the placing of plant protection products on the market and repealing Council Directives79/117/EEC and 91/414/EEC. http://eur-lex.europa.eu/legalcontent/EN/TXT/?uri celex%3A32009R1107Presentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 20167

The cables revealed (as reported by The Guardian) that the US embassyin Paris advised Washington to start a military-style trade war againstany European Union country that opposed GM crops.28In response to moves by France to ban a Monsanto GM corn variety inlate 2007, the ambassador, Craig Stapleton, a friend and businesspartner of former US president George Bush, asked Washington topenalise the EU and particularly countries which did not support the useof GM crops."Country team Paris recommends that we calibrate a target retaliation listthat causes some pain across the EU since this is a collectiveresponsibility, but that also focuses in part on the worst culprits."The list should be measured rather than vicious and must besustainable over the long term, since we should not expect an earlyvictory. Moving to retaliation will make clear that the current path has realcosts to EU interests and could help strengthen European pro-biotechvoices," said Stapleton, who with Bush co-owned the Dallas/Fort Worthbased Texas Rangers baseball team in the 1990s.In other cables, US diplomats around the world are found to havepushed GM crops as a strategic government and commercial imperative.In addition, the cables show US diplomats working directly for GMcompanies such as Monsanto. "In response to recent urgent requests bySpanish rural affairs ministry state secretary Josep Puxeu andMonsanto, post requests renewed US government support of Spain'sscience-based agricultural biotechnology position through high-level USgovernment intervention."Bribery in Indonesia: In 2005 the BBC reported that Monsanto hadagreed to pay a 1.5m ( 799,000) fine for bribing an Indonesian officialin a bid to avoid environmental impact studies being conducted on itsGM Bt insecticide-containing cotton.2928Vidal J, WikiLeaks: US targets EU over GM crops. The Guardian, 3 Jan /wikileaks-us-eu-gm-crops29BBC News. Monsanto fined 1.5m for bribery. 7 Jan tmPresentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 20168

Bt cotton was introduced in South Sulawesi province in 2001. Two yearslater it was withdrawn after its failure to perform triggered farmerprotests.30Smear campaigns against inconvenient studiesMonsanto has used underhand, deceptive, and non-transparent tacticsto try to discredit scientific studies that present results that threaten thecompany’s interests – and to smear the scientists concerned. In somecases Monsanto’s activities are overt, but more usually the company’sinterests and messages are represented and voiced by third parties suchas public relations firms or ostensibly independent academics andscientists (the “third-party” PR technique).Séralini study: In 2012 a long-term toxicity study was published31showing that two Monsanto products, a GM herbicide-tolerant maize(NK603) and the Roundup herbicide it was engineered to tolerate, hadtoxic effects on rats when fed over the long-term period of 2 years.Effects included liver and kidney damage in most treatment groups. Inaddition, a trend of increased tumour rates was found in most treatmentgroups, though this would have to be confirmed in a dedicated cancerstudy using larger numbers of animals.Within hours of the study’s publication, a massive public relationscampaign sprang into operation to try to discredit the study andpressurize the editor of the journal that published it, Food and ChemicalToxicology, to retract it.The PR campaign was marked by dishonest attacks on the science ofthe Séralini paper and a lack of transparency on the part of those behindthe campaign.Monsanto’s direct involvement lay in circulating quotes from third-partyexperts (a PR technique whereby corporate messages are put into themouths of supposedly independent experts) denigrating the study. Thequotes were collected and disseminated to the press by the UK ScienceMedia Centre, an organization that defends and promotes GM30GRAIN. Bt cotton - the facts behind the hype. January bt-cotton-the-facts-behind-the-hype31Séralini et al. RETRACTED: Long term toxicity of a Roundup herbicide and a Roundup-tolerantgenetically modified maize. Food Chem Toxicol. /science/article/pii/S0278691512005637Presentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 20169

technology and that is 70% funded by corporations,32 including Monsantoand other big GMO developer firms.33Monsanto’s influence in the smear campaign against Séralini alsoappears to have been exerted indirectly at one remove, through theinternet PR firm v-Fluence and the lobby group AgBioWorld, amongothers. v-Fluence has strong connections with Monsanto.GMWatch founder/director Jonathan Matthews describes these links andgives a full account of the anti-Séralini smear campaign in his article,“Smelling a corporate rat”.34 The article is reproduced below, with internallinks preserved and some updated links added.Quist/Chapela study: The article shows that the tactics used againstthe Séralini study were similar to those used over 10 years previouslyagainst the scientists Ignacio Chapela and David Quist, after theypublished their findings of GMO contamination of native Mexicanmaize.35 Many of the same Monsanto- and industry-linked actors wereinvolved in both smear campaigns.Smelling a corporate ratJonathan MatthewsSpinwatch, 11 Dec nce/item/164-smellinga-corporate-ratA new study suggesting a Monsanto GM maize and the company's Roundupherbicide may pose serious health risks has been widely attacked, not just byscientists and commentators but also by scientific bodies and regulators. Here,Jonathan Matthews of GMWatch looks at the role of industry-linkedscientists and lobbyists in a campaign aimed at getting the paper retracted.You can also download this article as a PDF.At the end of November Reuters ran the headline Science Journal Urgedto Retract Monsanto GM Study and New Scientist also reported thegrowing pressure for retraction. These articles marked the latest stage in acampaign that kicked off the moment the study was published in mid32Corporate Europe Observatory. Study on Monsanto's GM maize intensifies concerns about EFSA'sreliability – Monsanto strikes back with PR offensive. 21 Sept bility-monsanto-strikes-back-pr33Science Media Centre. Funding. 2012. http://bit.ly/11sRAzV.34Matthew J. Smelling a corporate rat. Spinwatch, 11 Dec ence/item/164-smelling-a-corporate-rat35Quist D, Chapela IH. Transgenic DNA introgressed into traditional maize landraces in Oaxaca,Mexico. Nature 414:541-543. ation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 201610

September, when researchers led by Prof. Gilles-Eric Séralini at theUniversity of Caen in France announced their findings of serious healthproblems in rats that had been fed a Monsanto maize geneticallyengineered to be resistant to the company's herbicide Roundup, as wellas in rats just fed low doses of the herbicide itself. In both cases the ratsfed with the GM maize and/or minute amounts of the herbicide in waterwere several times more likely to develop lethal tumours and suffer severeliver and kidney damage when compared to the controls.Science Media Centre spearheads the attackAlthough the publication of the results of the long-term feeding trial inFood and Chemical Toxicology made front page news in France, it got avery different reception in the English-speaking world. This was thanksto the rapid rebuttal efforts of the London-based Science Media Centre(SMC), which almost as soon as the study was published began spoonfeeding journalists with ready-made quotes from scientists savaging thestudy.The SMC's director Fiona Fox was subsequently reported as saying thatshe took pride in the fact that the SMC's "emphatic thumbs down hadlargely been acknowledged throughout UK newsrooms: apart from theMail, only the Daily Telegraph and the Financial Times covered thestory in their print editions – and both used quotes supplied by theScience Media Centre.” She added that several television newsprogrammes had also rejected the story after reading the quotes.The SMC's quotes were pumped out internationally via its clones, likethe Australian Science Media Centre, with like-minded local expertslayered on the top. The quotes were also circulated to the media byMonsanto and other GM lobby groups. As a result, the quotes ended upin a lot of media coverage worldwide. One even popped up in the NewYork Times along with the scathing comments of Bruce M. Chassy,professor emeritus of food science at the University of Illinois.Retraction campaign kicks inAnother key player in whipping up hostility to the paper was theAmerican business magazine Forbes. In the ten days following the study'srelease, Forbes published no less than six separate attack pieces targetingnot just the research but also the researchers. The first two pieces drewextensively on the quotes from the Science Media Centre and ran withthem, but the Forbes piece that grabbed the most attention, particularlyon social media, was one that kicked off with a headline that labelled thepaper a fraud. The article went on to accuse Prof. Séralini not just ofPresentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 201611

"gross scientific misconduct" but also of having "a long and sordidhistory" of "activism". The article concluded by bluntly telling theeditors of Food and Chemical Toxicology that the only "honorablecourse of action for the journal would be to retract the paperimmediately".The retraction campaign was by then well under way. An online petitionwas up and running, demanding in the name of "the scientificcommunity" that Séralini hand over all his raw data. The petition wasaggressively promoted via social media, often with the implication thatthe researchers had something to hide. The assertion that the study was"fraudulent" obviously played well into this campaign, which culminatedin the Reuters and New Scientist pieces reporting the retraction calls.Both these articles reported on the petition, as well as containinglacerating comments from two UK scientists – comments once againprovided by the Science Media Centre.One of the published comments – from Prof. Maurice Moloney – said itwas "appalling" that such a study should ever have been published in arespected journal. And a researcher from the UK's John Innes Centredemanded to know whether it was not "time for Food and ChemicalToxicology to retract the manuscript?" The only other scientist quotedclaimed the publication of the paper was more than just "a dangerouscase of failure of the peer-review system." It represented a threat to notjust the credibility of the journal but "the scientific method overall". Thisapocalyptic claim was backed up by the news that hundreds of outragedscientists had signed the online petition.Who's behind the retraction petition?Writing in The Guardian at the end of September, John Vidal describedthe attacks already raining down on Séralini and his team as "a triumphfor the scientific and corporate establishment which has used similartactics to crush other scientists". These included, Vidal said, "ArpadPusztai of the Rowett Institute in Scotland, who was sacked after hisresearch suggested GM potatoes damaged the stomach lining andimmune system of rats, and David Quist and Ignacio Chapela", whostudied the flow of genes from illegally planted GM maize to Mexicanindigenous maize.The vociferous attacks on Quist and Chapela resulted in the apparentretraction of their paper by the journal Nature, even though such a movewas not supported by the majority of its reviewers and subsequentPresentation to the Monsanto Tribunal by Claire Robinson, editor, GMWatch. October 201612

research confirmed the paper’s main finding.36 But, as the Frenchjournalist Benjamin Sourice has pointed out, the simplest way todefinitively discredit a study and nullify its impact is to pressurise thejournal that published it to retract it from its list o

another term with the same meaning: "comparative assessment" or "comparative safety assessment". The story of how the comparative safety assessment made its way into Europe's GMO regulatory system is a tale of revolving doors and conflicts of interest with industry. The change of name from "substantial equivalence" to "comparative

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