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

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 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 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. 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. Coexistence: VKM concludes that separation distances of 200 meters most likely will ensure coexistence between genetically modified maize and conventional and organic maize varieties in Norway. Overall Conclusion: Based on current knowledge, VKM concludes that maize Bt11 is nutritionally equivalent t

Final Health and Environmental Risk Assessment of Genetically Modified Maize MON 89034 x NK 603

In preparation for a legal implementation of EU-regulation 1829/2003, the Norwegian Scientific Committee for Food Safety (VKM) has been requested by the Norwegian Environment Agency (former Norwegian Directorate for Nature Management) and the Norwegian Food Safety Authority (NFSA) to conduct final food/feed and environmental risk assessments for all genetically modified organisms (GMOs) and products containing or consisting of GMOs that are authorized in the European Union under Directive 2001/18/EC or Regulation 1829/2003/EC. The request covers scope(s) relevant to the Gene Technology Act. The request does not cover GMOs that VKM already has conducted its final risk assessments on. However, the Agency and NFSA requests VKM to consider whether updates or other changes to earlier submitted assessments are necessary. The insect-resistant and glyphosate-tolerant genetically modified maize MON 89034 x NK 603 from Monsanto (Unique Identifier MON-89Ø34-3 × MON-ØØ6Ø3-6) was approved under Regulation (EC) No 1829/2003 in the EU for food and feed uses, import and processing on 28 July 2010 (Commission Decision 2010/420/EC). Genetically modified maize MON 890314 x NK 603 has previously been risk assessed by the VKM Panel on Genetically Modified Organisms (GMO), commissioned by the Norwegian Food Safety Authority and the Norwegian Environment Agency related and to the EFSA public hearing of the applications EFSA/GMO/NL/2007/38 and EFSA/GMO/NL/2009/72 in 2007 and 2009/2010 (VKM 2008a, VKM 2010a). In addition, the parental lines MON 89034 and NK 603 have been evaluated by the VKM GMO Panel as single events and as a component of several stacked GM maize events (VKM 2005a,b,c,d,e, VKM 2007a,b, VKM 2008b,c,d, VKM 2009a,b, VKM 2010 a,b, VKM 2011, VKM 2012a,b, VKM 2013 a,b, VKM 2014). The food/feed and environmental risk assessment of the maize MON 89034 x NK 603 is based on information provided by the applicant in the applications EFSA/GMO/NL/2007/38 EFSA/GMO/NL/2009/72 and scientific comments from EFSA and other member states made available on the EFSA website GMO Extranet. The risk assessment also considered other peer-reviewed scientific literature as relevant. The VKM GMO Panel has evaluated MON 89034 x NK 603 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 MON 89034 x NK 603 include molecular characterisation of the inserted DNA and expression of novel proteins, comparative assessment of agronomic and phenotypic characteristics, nutritional assessments, toxicology and allergenicity, unintended effects on plant fitness, potential for gene transfer, effects on biogeochemical processes and interactions between the GM plant and target and non-target organisms. It is emphasized that the VKM mandate does not include assessments of contribution to sustainable development, societal utility and ethical considerations, according to the Norwegian 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 Panel on Genetically Modified Organisms. Likewise, the VKM mandate does not include evaluations of herbicide residues in food and feed from genetically modified plants. The hybrid maize MON 89034 x NK 603 has been produced by conventional crosses between inbred lines containing MON 89034 and NK 603 events to combine resistance to certain lepidopteran pests and to confer tolerance towards glyphosate-containing herbicides. Maize MON 89034 was developed to provide protection against specific lepidopteran target pest, including Ostrinia nubilalis, S podoptera spp. and Agrotis ipsilon. Protection is achieved through expression in the plant of two insecticidal Cry proteins, Cry1A.105 and Cry2Ab2, derived from Baci llus thuringiensis subsp. a izawai and kurstaki. Maize NK 603 has been developed to provide tolerance to glyphosate by the introduction, of a gene coding for 5enolpyruvylshikimate-3-phosphate synthase (EPSPS) from Agrobacterium sp. strain CP4 (CP4 EPSPS). Molecular Characterisation: Southern and PCR analyses indicate that the recombinant inserts in the single maize events MON 89034 and NK 603 are retained in maize stack MON 89034 x NK603. Genetic stability of the inserts has previously been demonstrated in the parental lines MON 89034and NK603. The level of Cry1A.105, Cry2Ab2 and CP4 EPSPS proteins in grain and forage from the stacked event are comparable to the levels in the corresponding single events. Phenotypic analyses also indicate stability of the insect resistance and herbicide tolerance traits of the stacked event. Based on current knowledge and the previous assessments of the parental maize events, the VKM GMO Panel considers the molecular characterisation of maize MON 89034 x NK 603 satisfactory. 6 VKM Report 2016: 17. Comparative Assessment: The applicant has performed comparative analyses of data from field trials located at representative sites and environments in Argentina in 2004/2005 and Europe in 2007. With the exception of small intermittent variations and the insect resistance and herbicide tolerance conferred by the Cry1A.105, Cry2Ab2 and CP4 EPSPS proteins, the results showed no biologically relevant differences between maize stack MON 89034 x NK 603 and conventional control. Based on the assessment of available data, the VKM GMO Panel concludes that maize MON 89034 x NK 603 is compositionally, agronomical and phenotypically equivalent to its conventional counterpart, except for the new proteins. Food/feed Safety Assessment: A whole food feeding study on broilers has not indicated any adverse health effects of maize MON 89034 x NK 603, and shows that it is nutritionally equivalent to conventional maize varieties. The Cry1A.105, Cry2Ab2, and CP4 EPSPS proteins do not show sequence resemblance to other known toxins or IgE allergens, nor have they been reported to cause IgE mediated allergic reactions. However, some studies have indicated a potential role of Cry-proteins as adjuvants in allergic reactions. Based on current knowledge, the VKM GMO Panel concludes that maize MON 89034 x NK 603 is nutritionally equivalent to conventional maize varieties. It is unlikely that the Cry1A.105, Cry2Ab2, and CP4 EPSPS proteins will cause toxic or IgE-mediated allergic reactions to food or feed based on maize MON 89034 x NK 603 compared to conventional maize. Environmental Risk: Considering the intended uses of maize MON 89034 x NK603, excluding cultivation, the environmental risk assessment is concerned with accidental release into the environment of viable grains during transportation and processing, and indirect exposure, mainly through manure and faeces from animals fed grains from maize MON 89034 x NK603. Maize MON 89034 x NK 603 has no altered survival, multiplication or dissemination characteristics, and there are no indications of an increased likelihood of spread and establishment of feral maize plants in the case of accidental release into the environment of seeds from maize MON 89034 x NK603. Maize is the only representative of the genus Zea in Europe, and there are no cross-compatible wild or weedy relatives outside cultivation. The VKM GMO Panel considers the risk of gene flow from occasional feral GM maize plants to conventional maize varieties to be negligible in Norway. Considering the intended use as food and feed, interactions with the biotic and abiotic environment are not considered by the GMO Panel to be an issue. 7 VKM Report 2016: 17. Overall Conclusion: Based on current knowledge, the VKM GMO Panel concludes that maize MON 89034 x NK 603 is compositionally, nutritionally, agronomically and phenotypically equivalent to its conventional counterpart except for the new proteins. It is unlikely that the Cry1A.105, Cry2Ab2 and CP4 EPSPS proteins will cause an increased risk of toxic or IgE-mediated allergic reactions to food or feed based on maize MON 89034 x NK 603 compared to conventional maize varieties. The VKM GMO Panel concludes that maize MON 89034 x NK603, based on current knowledge, is comparable to conventional maize varieties concerning environmental risk in Norway with the intended usage.

Final Health- and Environmental Risk Assessment of Genetically Modified Maize MON 89034 x MON 88017

In preparation for a legal implementation of EU-regulation 1829/2003, the Norwegian Scientific Committee for Food Safety (VKM) has been requested by the Norwegian Environment Agency and the Norwegian Food Safety Authority (NFSA) to conduct final food/feed and environmental risk assessments for all genetically modified organisms (GMOs) and products containing or consisting of GMOs that are authorized in the European Union under Directive 2001/18/EC or Regulation 1829/2003/EC. The request covers scope(s) relevant to the Gene Technology Act. The request does not cover GMOs that VKM already has conducted its final risk assessments on. However, the Agency and NFSA requests VKM to consider whether updates or other changes to earlier submitted assessments are necessary. The insect-resistant and glyphosate-tolerant genetically modified maize MON 89034 x MON 88017 from Monsanto (Unique Identifier MON-89Ø34-3 × MON-88Ø17-3) was approved under Regulation (EC) No 1829/2003 in the EU for food and feed uses, import and processing on 17th of June 2011 (Commission Decision 2011/366/EC). Genetically modified maize MON 890314 x MON 88017 has previously been risk assessed by the VKM Panel on Genetically Modified Organisms (GMO), commissioned by the Norwegian Food Safety Authority and the Norwegian Environment Agency related and to the EFSA public hearing of the applications EFSA/GMO/NL/2007/39 and EFSA/GMO/BE/2009/71 in 2007 and 2009/2010 (VKM 2008a, VKM 2010a). In addition, the parental lines MON 89034 and MON 88017 have been evaluated by the VKM GMO Panel as single events and as a component of several stacked GM maize events (VKM 2007a,b, VKM 2008b, VKM 2009a,b,c, VKM 2010b,c, VKM 2012, VKM 2013, VKM 2014). The food/feed and environmental risk assessment of the maize MON 89034 x MON 88017 is based on information provided by the applicant in the applications EFSA/GMO/NL/2007/39 EFSA/GMO/BE/2009/71 and scientific comments from EFSA and other member states made available on the EFSA website GMO Extranet. The risk assessment also considered other peer-reviewed scientific literature when relevant. The VKM GMO Panel has evaluated MON 89034 x MON 88017 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 2010), 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 MON 89034 x MON 88017 include molecular characterisation of the inserted DNA and expression of novel proteins, comparative assessment of agronomic and phenotypic characteristics, nutritional assessments, toxicology and allergenicity, unintended effects on plant fitness, potential for gene transfer, effects on biogeochemical processes and interactions between the GM plant and target and non-target organisms. 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 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 Panel on Genetically Modified Organisms. Likewise, the VKM mandate does not include evaluations of herbicide residues in food and feed from genetically modified plants.The hybrid maize MON 89034 x MON 88017 has been produced by conventional crosses between inbred lines containing MON 89034 and MON 88017 events to combine resistance to certain coleopteran and lepidopteran pests, and to confer tolerance towards glyphosate-containing herbicides. Maize MON 89034 was developed to provide protection against specific lepidopteran target pest, including Ostrinia nubilalis , S podoptera spp. and Agrotis ipsilon. Protection is achieved through expression in the plant of two insecticidal Cry proteins, Cry1A.105 and Cry2Ab2, derived from Bacillus thuringiensis subsp. a izawai and kurstaki. Maize MON 88017 was developed to express a modified Cry3Bb1 insecticidal protein, derived from B. thuringiensis subsp. kumamotoensis , which confers protection against coleopteran target pests belonging to the genus Diabrotica such as Western corn rootworm ( D . virgifera virgifera ). MON 88017 is also developed to provide tolerance to the herbicidal active substance glyphosate by the introduction of a gene coding for the enzyme 5enolpyruvylshikimate-3-phosphate synthase (EPSPS), from Agrobacterium tumefaciens strain CP4 (CP4 EPSPS). Molecular Characterisation: Southern and PCR analyses indicate that the recombinant inserts in the single maize events MON 89034 and MON 88017 are retained in the stacked event MON 89034 x MON 88017. Genetic stability of the inserts has previously been demonstrated in the single events. The levels of Cry1A.105, Cry2Ab2, CP4 EPSPS and Cry3Bb1 proteins in grain and forage from the stacked event are comparable to the levels in the corresponding single events. Phenotypic analyses also indicate stability of the insect resistance and herbicide tolerance traits of the stacked event. Based on current knowledge and the previous assessments of the parental maize events, the VKM GMO Panel considers the molecular characterisation of maize MON 89034 x MON 88017 satisfactory. Comparative Assessment: Comparative analyses of maize MON 89034 x MON 88017 and its conventional counterpart have been performed by the applicant during field trials located at representative sites and environments in USA during 2004, and in Europe in 2007. Several different conventional maize varieties were included in the field trials and used as references. With the exception of small variations, and the insect resistance and herbicide tolerance conferred by the Cry3Bb1, Cry1A105, Cry2Ab2, and CP4 EPSPS proteins, the results from these studies showed no biologically relevant differences between the maize stack MON 89034 x MON 88017 and its conventional counterpart. Based on the assessment of available data, the VKM GMO Panel concludes that maize MON 89034 x MON 88017 is compositionally, agronomically and phenotypically equivalent to its conventional counterpart, except for the new proteins. Food and Feed Safety Assessment: A whole food feeding study performed on broilers indicates no adverse health effects of maize MON 89034 x MON 88017, and shows that it is nutritionally equivalent to conventional maize varieties. The Cry1A.105, Cry2Ab2, Cry3Bb1 and CP4 EPSPS proteins do not show relevant sequence resemblance to other known toxins or IgE-allergens, nor have they been reported to cause IgE-mediated allergic reactions. However, some studies have indicated a potential role of Cry-proteins as adjuvants in allergic reactions. Based on current knowledge, the VKM GMO Panel concludes that maize MON 89034 x MON 88017 is nutritionally equivalent to conventional maize varieties. It is unlikely that the Cry1A.105, Cry2Ab2, Cry3Bb1 and CP4 EPSPS proteins will cause toxic or IgE-mediated allergic reactions to food or feed derived from maize MON 89034 x MON 88017 compared to conventional maize. Environmental Risk: Considering the intended uses of maize MON 89034 x MON 88017, excluding cultivation, the environmental risk assessment is concerned with accidental release into the environment of viable grains during transportation and processing, and indirect exposure, mainly through manure and faeces from animals fed grains from maize MON 89034 x MON 88017. Maize MON 89034 x MON 88017 has no altered survival, multiplication or dissemination characteristics, and there are no indications of an increased likelihood of spread and establishment of feral maize plants in the case of accidental release into the environment of seeds from maize MON 89034 x MON 88017. Maize is the only representative of the genus Zea in Europe, and there are no cross-compatible wild or weedy relatives outside cultivation. The VKM GMO Panel considers the risk of gene flow from occasional feral GM maize plants to conventional maize varieties to be negligible in Norway. Considering the intended use as food and feed, interactions with the biotic and abiotic environment are not considered by the GMO Panel to be an issue. Overall Conclusion: Based on current knowledge, the VKM GMO Panel concludes that maize MON 89034 x MON 88017 is compositionally, nutritionally, agronomically and phenotypically equivalent to its conventional counterpart except for the new proteins. It is unlikely that the Cry1A.105, Cry2Ab2, CryBb1 and CP4 EPSPS proteins will cause an increased risk of toxic or IgE-mediated allergic reactions to food or feed based on maize MON 89034 x MON 88017 compared to conventional maize varieties. The VKM GMO Panel concludes that maize MON 89034 x MON 88017, based on current knowledge, is comparable to conventional maize varieties concerning environmental risk in Norway with the intended usage.

Final Health- and Environmental Risk Assessment of Genetically Modified Maize MON 88017 x MON 810

In preparation for a legal implementation of EU-regulation 1829/2003, the Norwegian Scientific Committee for Food Safety (VKM) has been requested by the Norwegian Environment Agency and the Norwegian Food Safety Authority (NFSA) to conduct final food/feed and environmental risk assessments for all genetically modified organisms (GMOs) and products containing or consisting of GMOs that are authorized in the European Union under Directive 2001/18/EC or Regulation 1829/2003/EC. The request covers scope(s) relevant to the Gene Technology Act. The request does not cover GMOs that VKM already has conducted its final risk assessments on. However, the Agency and NFSA requests VKM to consider whether updates or other changes to earlier submitted assessments are necessary. The insect-resistant and glyphosate-tolerant genetically modified maize MON 88017 x MON 810 from Monsanto (Unique Identifier DAS-MON 88017-3 x MON-ØØ81Ø-6) was approved under Regulation (EC) No 1829/2003 in the EU for food and feed uses, import and processing on 28th of July 2010 (Commission Decision 2010/429/EC). Genetically modified maize MON 88017 x MON 810 has previously been risk assessed by the VKM Panel on Genetically Modified Organisms (GMO), commissioned by the Norwegian Food Safety Authority related to the EFSA public hearing of the application in 2007 (VKM 2007a). In addition, MON 88017 and MON 810 has been evaluated by the VKM GMO Panel as single events and as a component of several stacked GM maize events and Regulation (EC) 1829/2003 and Directive 2001/18/EC (VKM 2005a,b,c, VKM 2007b,c,d, VKM 2008, VKM 2009, VKM 2010 a,b,c, VKM 2012, VKM 2013, VKM 2016). The food/feed and environmental risk assessment of the maize MON 88017 x MON 810 is based on information provided by the applicant in the application EFSA/GMO/CZ/2006/33 and scientific comments from EFSA and other member states made available on the EFSA website GMO Extranet. The risk assessment also considered other peer-reviewed scientific literature as relevant. The VKM GMO Panel has evaluated MON 88017 x MON 810 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 2010), 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 MON 88017 x MON 810 include molecular characterisation of the inserted DNA and expression of novel proteins, comparative assessment of agronomic and phenotypic characteristics, nutritional assessments, toxicology and allergenicity, unintended effects on plant fitness, potential for gene transfer, effects on biogeochemical processes and interactions between the GM plant and target and non-target organisms. It is emphasized that the VKM mandate does not include assessments of contribution to sustainable development, societal utility and ethical considerations, according to the Norwegian 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 Panel on Genetically Modified Organisms. Likewise, the VKM mandate does not include evaluations of herbicide residues in food and feed from genetically modified plants. The hybrid maize MON 88017 x MON 810 was produced by conventional crosses between inbred lines containing MON 88017 and MON 810 events to combine resistance to certain coleopteran and lepidopteran pests, and to confer tolerance towards glyphosate-containing herbicides. Maize MON 88017 was developed to express a modified Cry3Bb1 insecticidal protein, derived from Bacillus thuringiensis subsp. kumamotoensis , which confers protection against coleopteran target pests belonging to the genus Diabrotica such as Western corn rootworm ( Diabrotica virgifera virgifera ). MON 88017 is also developed to provide tolerance to the herbicidal active substance glyphosate by the introduction of a gene coding for the enzyme 5-enolpyruvylshikimate-3-phosphate synthase (EPSPS), from Agrobacteri um tumefaciens strain CP4 (CP4 EPSPS). Maize MON 810 expresses the Cry1Ab insecticidal protein, derived from Bacillus thuringiensis subsp. k u rstaki, which confers protection against lepidopteran pests such as Ostrinia nubilaris and species belonging to the genus Sesamia. Molecular characterisation Southern and PCR analyses indicate that the recombinant inserts in the single maize events MON 88017 and MON 810 are retained in the stacked event MON 88017 x MON 810. Genetic stability of the inserts has previously been demonstrated in the single events. The levels of CP4 EPSPS, Cry3Bb1 and Cry1Ab proteins in grain and forage from the stacked event are comparable to the levels in the corresponding single events. Phenotypic analyses also indicate stability of the insect resistance and herbicide tolerance traits of the stacked event. Based on current knowledge and the previous assessments of the parental maize events, the VKM GMO Panel considers the molecular characterisation of maize MON 88017 x MON 810 satisfactory. Comparative assessment The applicant has performed comparative analyses of data from field trials located at representative sites and environments in USA during the 2002 growing season. With the exception of small intermittent variations and the insect resistance and herbicide tolerance conferred by the CP4 EPSPS, Cry3Bb1 and Cry1Ab proteins, the results showed no biologically relevant differences between maize stack MON 88017 x MON 810 and its conventional counterpart. Based on the assessment of available data, the VKM GMO Panel concludes that maize MON 88017 x MON 810 is compositionally, agronomically and phenotypically equivalent to its conventional counterpart, except for the new proteins. Food and feed safety assessment A whole food feeding study on broilers indicates no adverse health effects of maize MON 88017 x MON 810, and shows that it is nutritionally equivalent to conventional maize varieties. The Cry3Bb1, Cry1Ab and CP4 EPSPS proteins do not show relevant sequence resemblance to other known toxins or IgE-allergens, nor have they been reported to cause IgE-mediated allergic reactions. However, some studies have indicated a potential role of Cry-proteins as adjuvants in allergic reactions. Based on current knowledge, the VKM GMO Panel concludes that maize MON 88017 x MON 810 is nutritionally equivalent to conventional maize varieties. It is unlikely that the Cry3Bb1, Cry1Ab and CP4 EPSPS proteins will cause toxic or IgE-mediated allergic reactions to food or feed based on maize MON 88017 x MON 810 compared to conventional maize. Environmental risk assessment Considering the intended uses of maize MON 88017 x MON 810, excluding cultivation, the environmental risk assessment is concerned with accidental release into the environment of viable grains during transportation and processing, and indirect exposure, mainly through manure and faeces from animals fed grains from maize MON 88017 x MON 810. Maize MON 88017 x MON 810 has no altered survival, multiplication or dissemination characteristics, and there are no indications of an increased likelihood of spread and establishment of feral maize plants in the case of accidental release into the environment of seeds from maize MON 88017 x MON 810. Maize is the only representative of the genus Zea in Europe, and there are no cross-compatible wild or weedy relatives outside cultivation. The VKM GMO Panel considers the risk of gene flow from occasional feral GM maize plants to conventional maize varieties to be negligible in Norway. Considering the intended use as food and feed, interactions with the biotic and abiotic environment are not considered by the GMO Panel to be an issue. Overall conclusion Based on current knowledge, the VKM GMO Panel concludes that maize MON 88017 x MON 810 is compositionally, nutritionally, agronomically and phenotypically equivalent to its conventional counterpart except for the new proteins. It is unlikely that the Cry3Bb1, Cry1Ab and CP4 EPSPS proteins will cause an increased risk of toxic or IgE-mediated allergic reactions to food or feed based on maize MON 88017 x MON 810 compared to conventional maize varieties. The VKM GMO Panel concludes that maize MON 88017 x MON 810, based on current knowledge, is comparable to conventional maize varieties concerning environmental risk in Norway with the intended usage.

Final Health- and Environmental Risk Assessment of Genetically Modified Maize MON 88017

In preparation for a legal implementation of regulation 1829/2003, the Norwegian Scientific Committee for Food Safety (VKM) has been requested by the Norwegian Environment Agency and the Norwegian Food Safety Authority (NFSA) to conduct final food/feed and environmental risk assessments for all genetically modified organisms (GMOs) and products containing or consisting of GMOs that are authorized in the European Union under Directive 2001/18/EC or Regulation 1829/2003/EC. The request covers scope(s) relevant to the Gene Technology Act. The request does not cover GMOs that VKM already has conducted its final risk assessments on. However, the Agency and NFSA requests VKM to consider whether updates or other changes to earlier submitted assessments are necessary. The insect-resistant and glyphosate-tolerant genetically modified maize MON 88017 from Monsanto (Unique Identifier DAS-MON 88017-7) was approved in the EU under Regulation (EC) No 1829/2003 for food and feed uses, import and processing the 30th of October 2009 (Commission Decision 2009/814/EC). Genetically modified maize MON 88017 has previously been risk assessed by the VKM Panel on Genetically Modified Organisms (GMO), commissioned by the Norwegian Food Safety Authority and the Norwegian Environment Agency related and to the EFSA public hearing of the applications EFSA/GMO/CZ/2005/27 and EFSA/GMO/CZ/2008/54 in 2007 and 2010 (VKM 2007a, 2010a). In addition, MON 88017 has been evaluated by the VKM GMO Panel as a component of several stacked GM maize events and Regulation (EC) 1829/2003 (VKM 2007b, VKM 2008, VKM 2009, VKM 2010b). The food/feed and environmental risk assessment of the maize MON 88017 is based on information provided by the applicant in the applications EFSA/GMO/UK/2005/27 and EFSA/CZ/2008/CZ/2008/54, and scientific comments from EFSA and other member states made available on the EFSA website GMO Extranet. The risk assessment also considered other peer-reviewed scientific literature as relevant. The VKM GMO Panel has evaluated MON 88017 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). 8.04.2016 The scientific risk assessment of maize MON 88017 include molecular characterisation of the inserted DNA and expression of novel proteins, comparative assessment of agronomic and phenotypic characteristics, nutritional assessments, toxicology and allergenicity, unintended effects on plant fitness, potential for gene transfer, interactions between the GM plant and target and non-target organisms, effects on biogeochemical processes. 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 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 Panel on Genetically Modified Organisms. Genetically modified maize MON 88017 expresses a Cry3Bb1 insecticidal protein, derived from Bacillus thuringiensis subsp. kumamotoensis, which confers protection against coleopteran target pests belonging to the genus Diabrotica such as Western corn rootworm (Diabrotica virgifera virgifera). MON 88017 is also developed to provide tolerance to the herbicidal active substance glyphosate by the introduction of a gene coding for the enzyme 5-enolpyruvylshikimate-3-phosphate synthase (EPSPS), from Agrobacterium tumefaciens strain CP4 (CP4 EPSPS). Molecular characterisation The molecular characterisation data has established that only one copy of the transgene is integrated in the maize genomic DNA. Appropriate analyses of the integration site including sequence determination of the inserted DNA and flanking regions and bioinformatics analysis have been performed. Bioinformatics analyses of junction regions have demonstrated the absence of any potential new ORFs coding for known toxins or allergens. The genetic stability of transformation event MON 88017 was demonstrated at the genomic level over multiple generations by Southern analysis. Segregation analysis shows that event MON 88017 is inherited as a dominant, single locus trait. The VKM GMO Panel considers the molecular characterisation of maize MON 88017 satisfactory. Comparative assessment Comparative analyses of maize MON 88017 and its conventional counterpart have been performed during field trials located at representative sites and environments in Europe and USA. A total of 12-16 different conventional maize varieties were included in the field trials and used as references. With the exception the insect resistance and herbicide tolerance conferred by the Cry3Bb1 and CP4 EPSPS proteins, no biologically relevant differences were found between maize MON 88017 and controls. Based on the assessment of available data, the VKM GMO Panel concludes that maize MON 88017 is compositionally, agronomically and phenotypically equivalent to its conventional counterpart except for the new proteins. 8.04.2016 VKM Report 2016:12 Food and feed safety assessment Whole food feeding studies on rats and broilers indicate no adverse health effects of maize MON 88017. These studies also show that maize MON 88017 is nutritionally equivalent to conventional maize. The Cry3Bb1 and CP4 EPSPS proteins do not show relevant sequence resemblance to other known toxins or IgE-allergens, nor have they been reported to cause IgE-mediated allergic reactions. However, some studies have indicated a potential role of Cry-proteins as adjuvants in allergic reactions. Based on current knowledge, the VKM GMO Panel concludes that maize MON 88017 is nutritionally equivalent to conventional maize varieties. It is unlikely that the Cry3Bb1 and CP4 EPSPS proteins will cause toxic or IgE-mediated allergic reactions to food or feed based on maize MON 88017 compared to conventional maize. Environmental risk assessment Considering the intended uses of maize MON 88017, excluding cultivation, the environmental risk assessment is concerned with accidental release into the environment of viable grains during transportation and processing, and indirect exposure, mainly through manure and faeces from animals fed grains from maize MON 88017. Maize MON 88017 has no altered survival, multiplication or dissemination characteristics, and there are no indications of an increased likelihood of spread and establishment of feral maize plants in the case of accidental release into the environment of seeds from maize MON 88017. Maize is the only representative of the genus Zea in Europe, and there are no cross-compatible wild or weedy relatives outside cultivation. The VKM GMO Panel considers the risk of gene flow from occasional feral GM maize plants to conventional maize varieties to be negligible in Norway. Considering the intended use as food and feed, interactions with the biotic and abiotic environment are not considered by the GMO Panel to be an issue. 8.04.2016. VKM Report 2016:12 Overall conclusion Based on current knowledge, the VKM GMO Panel concludes that maize MON 88017 is compositionally, nutritionally, agronomically and phenotypically equivalent to its conventional counterpart except for the new proteins. It is unlikely that the Cry3Bb1 and CP4 EPSPS proteins will cause an increased risk of toxic or IgE-mediated allergic reactions to food or feed based on maize MON 88017 compared to conventional maize. The VKM GMO Panel concludes that maize MON 88017, based on current knowledge, is comparable to conventional maize varieties concerning environmental risk in Norway with the intended usage.

Risk Assessment of Insect-resistant and Herbicide Tolerant Genetically Modified Maize 1507 for Cultivation, Import, Processing, Food and Feed Uses under Directive 2001/18/EC and Regulation (EC) No 1829/2003

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 associated with import of seeds for sowing, and cultivation of insect-resistant and herbicide-tolerant genetically modified maize 1507 under Directive 2001/18/EC (Notification C/ES/01/01). 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 VKM delivered a scientific opinion on this application including cultivation in 2014 (VKM, 2014), VKM is asked to assess whether the previous risk assessment is still valid concerning cultivation, and to update the opinion after current knowledge. The assessment shall specifically consider Norwegian conditions. Furthermore, as the notification does not cover food and feed uses of maize 1507, VKM was not asked for a health risk assessment of maize 1507. However, VKM has decided to update the previous safety evaluation of the food and feed uses of maize 1507 and derived products from 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 has assessed and approved the final report. The genetically modified maize 1507 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 synthetic version of the truncated c ry1F gene derived from Bacillus thuringiensis subsp. aizawai, a common soil bacterium. Maize 1507 also expresses the phosphinothricin - N - acetyltransferase (pat) gene, derived from the soil bacterium Streptomyces viridochromogenes. PAT protein confers tolerance to the herbicidal active substance glufosinate-ammonium. The PAT protein expressed in maize 1507 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/ES/01/01 does not cover the use of glufosinate-ammonium-containing herbicides on maize 1507, potential effects due to the use of such herbicides on maize 1507 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 notifications C/ES/01/01, C/NL/00/10, the applications EFSA/GMO/NL/2004/02 and EFSA/GMO/RX/1507, and scientific opinions and comments from EFSA and other EU member states. VKM has evaluated maize 1507 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. VKM has also decided to take into account, 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 opinion of maize 1507 include 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 postmarket environmental monitoring plan and coexistence measures at the farm level has also been undertaken. It is emphasised that VKM’s mandate does not include assessments of contribution to sustainable development, societal utility and ethical considerations, according to the Norwegian 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 VKM. Molecular Characterization: Appropriate analyses of the transgenic DNA insert, its integration site, number of inserts and flanking sequences in the maize genome, have been performed. The results show that one copy only of the insert is present in maize 1507. Homology searches with databases of known toxins and allergens have not indicated any potential production of harmful proteins or polypeptides caused by the genetic modification in maize 1507. Southern blot analyses and segregation studies show that the introduced genes cry1F and pat are stably inherited and expressed over several generations along with the phenotypic characteristics of maize 1507. VKM considers the molecular characterisation of maize 1507 satisfactory. Comparative Assessment: Comparative analyses of maize 1507 to its non-GM conventional counterpart have been performed during multiple field trials located at representative sites and environments in Chile (1998/99), USA (1999) and in Europe (1999, 2000 and 2002). With the exception of small intermittent variations, no biologically significant differences were found between maize 1507 and the conventional maize. Based on the assessment of available data, VKM concludes that maize 1507 is compositionally, agronomically and phenotypically equivalent to its conventional counterpart, except for the introduced characteristics, and that its composition fell within the normal ranges of variation observed among non-GM varieties. The field evaluations support a conclusion of no phenotypic changes indicative of increased plant weed/pest potential of 1507 compared to conventional maize. Food and Feed Safety Assessment: Whole food feeding studies on rats, broilers, pullets, pigs and cattle have not indicated any adverse health effects of maize 1507. These studies further indicate that maize 1507 is nutritionally equivalent to conventional maize. The PAT and Cry1F 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, VKM concludes that maize 1507 is nutritionally equivalent to conventional maize varieties. It is unlikely that the PAT and Cry1F proteins will introduce a toxic or allergenic potential in food or feed based on maize 1507 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 1507 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 1507 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. There are a limited number of published scientific studies on environmental effects of Cry1F protein. Published scientific studies show that the likelihood of negative effects of Cry1F protein on non-target arthropods that live on or in the vicinity of maize plants is low. 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 Cry1F-containing maize pollen on non-target lepidopteran species in Norway is therefore negligible. Cultivation of maize 1507 is not considered to represent a threat to the prevalence of red-listed species in Norway. Exposure of non-target 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 Cry1F protein and its potential interactions in soil are limited, the relevant scientific publications analysing the Cry1F 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 c