If you want to make corn-based ethanol, one of the first things you need to do is grind up the corn, mix the resulting flour with water and a couple of specialized enzymes, and cook it.
The first enzyme, alpha amylase, helps break down the large corn starch molecules into short sections. The second enzyme, gluco amylase, breaks the shorter sections into glucose sugar molecules. Once you've got the sugar, you can then add yeast, ferment and, voilà, alchohol!
As the craze for corn-based ethanol surges in the United States, commercially providing ever-improved versions of these enzymes has become a thriving business. But to ethanol producers, obtaining the enzymes represents a production cost that they'd rather do without.
One solution is to have corn arrive at the ethanol plant with the enzyme already preloaded. In August, Syngenta, the huge agribusiness biotech firm headquartered in Switzerland, applied for regulatory approval in New Zealand for permission to start growing transgenic corn purposefully optimized for the production of ethanol. Referred to as "Line 3272 corn," it is a strain of maize genetically modified to include an alpha amylase gene known as amy797E. Amy797E is hot stuff -- it is "thermostable" to the point that it can survive in boiling water, which makes it especially ideal for cooking corn-flour.
Line 3272, theoretically, would bring down costs for ethanol producers by simplifying their production processes. No need to add this enzyme -- it comes pre-mixed!
But here's the first problem: Corn is fabulously promiscuous. If you plant a field of transgenic corn destined solely for ethanol production, that corn will interbreed with other fields of corn. Barring further advances in gene containment technology that have yet to be perfected, energy crop corn will get into the food supply. This is not alarmist anti-GMO propaganda. It is fact. Everyone involved with the production and regulation of transgenic corn is well aware of this.
Which is why any new transgenic corn, no matter what its ultimate purpose, must pass the same safety and health safeguards that any new crop designed specifically for human consumption must go through.
But here's the second problem: According to the Centre for Integrated Research in Biosafety (CIRB) at the University of Canterbury in New Zealand, a key part of the regulatory safety process is in danger of being undermined. (Thanks to Denise Caruso for passing on the alert.)
CIRB's warning focuses on a New Zealand case in which Monsanto is applying for regulatory approval to sell transgenic corn optimized to contain high amounts of lysine. The corn is meant to be used exclusively for animal feed (apparently, lots of lysine makes it easier for animals to digest) but, again, since it is corn, and likes to get down and dirty with all other corn, it has to be assumed that transgenic high lysine corn will get into the food supply.
CIRB is concerned that there are health risks to high lysine corn that are not being adequately addressed by the regulatory authorities. But they are particularly alarmed at Monsanto's attempt to evade an established step in the regulatory review.
The baseline for assessing the safety of a GM food has always been to compare its genomic changes and composition with its closest non-GM relative, usually the parental variety from which the GM crop was made. This non-GM "comparator" is the standard baseline because it has a long history of safe use as a food for people.
An audacious bid is now being made to abandon this baseline by having a GM crop assessed for safety by comparing it to another GM variety that has no history of safe use. Regulators that ignore the normal requirement risk exposing themselves to litigation by developers of future GM crops should they try to re-assert the proper standard again later.
More detail about the Centre for Integrated Research in Biosafety's critique can be found here. But regardless of what position you take on whether humans should be eating super-lysine impregnated corn chips, or even whether the other strain of corn that Monsanto wants to use as a "comparator" can be deemed safe or not, the principle at issue here is the critical point. As the alert from CIRB notes, Syngenta is applying for approval of a strain of corn designated for ethanol production. A flood of similar innovations is no doubt set to follow. Crops of all kinds are going to have genes of all varieties inserted into them to optimize them for energy production. Intuitively, one suspects that corn and sugar cane and cassava that are industrially designed to produce fuel won't necessarily be the most nutritious substances for human ingestion.
Isn't it an absolute no-brainer that the regulatory process needs to be as pain-in-the-ass cautious and stringent as possible in such matters?
After all, even with the best of intentions, mistakes can and will happen. On Dec. 21, Syngenta paid a fine of $1.5 million to the EPA, settling a case in which it had accidentally planted unapproved transgenic corn. Apparently, the company confused one strain, that was approved, with another, that wasn't.