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Plants > Biotechnology / PNTs > Notices of Submission 

Notice of Submission for Approval of Novel Food and Livestock Feed Use that Includes an Environmental Safety Assessment of Cotton Genetically Modified For Herbicide Tolerance from Monsanto Canada Inc.

Date Posted: August 13, 2004

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To provide comments on this submission, please use the feedback form.

Background

The CFIA and Health Canada (HC) have received a submission from Monsanto Canada Inc. seeking livestock feed and food use approvals that includes an environmental safety assessment of cotton designated as MON 88913, which has been genetically modified for glyphosate herbicide tolerance. Cotton is not grown in Canada, and commercial cotton is not adapted to environmental conditions found in Canada. As such, Mon 88913 is not intended for commercial planting or seed production purposes in Canada. The submission received is in accordance with CFIA guidelines for assessment of novel feeds, and Health Canada guidelines for assessment of novel foods. To view information related to the environmental assessment of a plant with novel trait (PNT) or a novel feed, please refer to the CFIA Web site. To view the information related to the health and safety assessment of a novel food, please refer to the Health Canada Web site.

 

Summary of the Submission Package

Updated scientific information may be added to this submission by the developer at a later date, or CFIA and/or Health Canada may request further information from the developer.

Description of the host plant The Biology of Gossypium species (Cotton) at:  http://www.aphis.usda.gov/brs/biology.html. Cotton is not grown in Canada.
Description of the Modification The PNT was developed through recombinant DNA technology. In order to assess the modification process the following has been submitted:
  • Characterization of the transformation system/modification process
  • Description of the transformation method
  • Description of the genetic material delivered to the plant
  • Components of the vector
  • Summary of all genetic components
  • Description of the herbicide tolerance gene – CP4 EPSPS
  • Description of the promoters and polyadenylation sequences
  • Portion and size of the inserted sequence
  • Location, order and orientation in the vector
  • Function of the CP4 EPSPS gene in the plant
  • Source of the CP4 EPSPS gene (donor organism – bacteria)
  • Level of the CP4 EPSPS protein in cotton
  • Review of the toxicity and pathogenic ability of the genetic component to plants and other organisms
  • Review of the toxicity and pathogenic ability of the donor organism to plants and other organisms
  • History of use of the vector
  • Detailed map of the vector
Inheritance and Stability of the Introduced Trait In order to assess the inheritance and stability of the genetic modification the following has been submitted:
  • Generational stability analysis through five generations
Description of the Novel Traits In order to characterize the DNA inserted in the plant, the following has been submitted:
  • Information for all coding areas
  • Information for all plant promoters: Southern analysis of the CP4 EPSPS coding regions and their promoters
  • DNA analysis for introns, enhancers, and polyadenylation sequences of the plant expressible cassettes
  • Analysis for other promoters and regions associated with bacteria expressible cassettes and backbone regions of the vector outside of the T-DNA region.
  • Characterization of expressed CP4 EPSPS  protein in cotton tissues
Toxicity of the Novel Gene Products The toxicity of the cp4 epsps  gene on nontarget species, humans and animals have been previously submitted, reviewed, and published. Therefore, the following partial list of references and data were provided in the submission.
  • Decision Document DD97-21: Determination of the Safety of Cotton Lines with Roundup Ready® Genes (Gossypium hirsutum L.).
  • Decision Document DD95-02: Determination of Environmental Safety of Monsanto Canada Inc.’s Roundup Ready® Herbicide-Tolerant Brassica napus Canola Line GT73.
  • Decision Document DD95-05: Determination of Environmental Safety of Monsanto Canada Inc.’s Glyphosate Tolerant Soybean (Glycine max L.) Line GTS 40-3-2.
  • Decision Document 2002-35: Determination of Safety of Monsanto Canada Inc.’s Roundup Ready® Corn (Zea mays L.) Line 603
  • Assessment of the in vitro digestive fate of CP4 EPSPS synthase and purified E. coli produced CP4 EPSPS protein.
  • Bioinformatics analysis of the CP4 EPSPS protein utilizing the AD4, TOXIN5, and ALLPEPTIDES databases.
  • Harrison, L., M. Bailey et al. 1996. The expressed protein in glyphosate tolerant soybean, 5-EPSPS from Agrobacterium sp. Strain CP4, is rapidly digested in vitro and is not toxic to acutely gavaged mice. Journal of Nutrition 126: 728-739.
  • Petty, A.T., G.F. Hartnell et al. 2001. Performance of beef cattle fed Roundup Ready Corn harvested as whole plant silage or grain. J. Anim. Sci. 79(Suppl. 2):102. Abstract 321.
  • Donkin, S.S., G.F. Hartnell et al. 2000. Effect of feeding Roundup Ready Corn silage and grain on feed intake, milk production, and milk composition in lactating dairy cattle. J. Dairy Sci. 83 (Suppl. 1): 273 Abstract 1144.
  • Hammond, B. R.L. Fuchs et al. 1996. The feeding value of soybeans fed to rats, chickens, catfish, and dairy cattle is not altered by genetic incorporation of glyphosate tolerance. J. Nutr. 126: 717-727.
  • Castillo, A.R., G.F. Hartnell et al. 2001. Effect of feeding dairy cows with cottonseeds containing Bollgard and Roundup Ready genes or control non-transgenic cottonseeds on feed intake, milk yield and milk composition. J. Dairy Sci. 84(Suppl. 1) 413. Abstract 1713.
  • Aalhus, J.L., M.E.R. Dugan, K.A. Lien, I.L. Larsen, F. Costello, D.C. Roland, D.R. Best and R.D. Thacker. 2003. Effects of feeding glyphosate-tolerant canola meal on swine growth, carcass composition and meat quality. J. Anim. Sci. 81:3267.
  • Stanford, K., J.L. Aalhus, M.E.R. Dugan, G.L. Wallins, R. Sharma, T.A. McAllister. 2003. Effects of feeding transgenic canola on apparent digestibility, growth performance and carcass characteristics of lambs. Canadian J. Anim. Sci. 83(2):299-305.
Nutritional Evaluation of the Novel Plant In order to assess nutritional aspects of the novel plant products the following has been submitted:
  • The nutritional composition of the novel plant products has been compared to the appropriate negative segregant control. The following have been considered:
    • Proximate composition (protein, fat, ash, carbohydrates)
    • Composition of fiber, amino acids and minerals
    • Composition comparison of fatty acid, vitamins and Gossypol
Allergenicity/Toxicity Considerations In order to assess allergenicity of the novel protein the following has been submitted:
  • Comparison of the amino acid sequence similarity of CP4 EPSPS protein to known allergen proteins bioinformatics analysis
  • Digestive fate in vitro studies
Evaluation of the Environmental Impact of the Novel Plant In order to assess the environmental impact of the novel plant the previous approvals for cotton have been referenced.

Comments will be received only via the Internet or postal mail to CFIA or Health Canada. (See addresses below.)

Monsanto Canada Inc.
130 Albert Street, Suite 1902
Ottawa ON
K1P 5G4

For more information on the regulatory system, please contact:

Feed Section
Animal Products Directorate
Canadian Food Inspection Agency
59 Camelot Drive
Nepean, Ontario
K1A 0Y9
(613) 225-2342

Novel Foods Section
Food Directorate
Health Products and Food Branch
Health Canada
Tunney’s Pasture
Ottawa, Ontario
K1A 0L2
(613) 954-8921
Plant Biosafety Office
Plant Products Directorate
Canadian Food Inspection Agency
59 Camelot Drive
Nepean, Ontario
K1A 0Y9
(613) 225-2342

The CFIA and Health Canada, including their employees, are not responsible for the content of this Notice of Submission as submitted by the Applicant. All Notices of Submission are the responsibility of the Applicant submitting them and the Applicant does so at its own risk. Submission of this Notice of Submission and its subsequent posting by the CFIA on its Web site does not in any way whatsoever constitute acceptance, approval or certification by the CFIA or Health Canada of the Plant with Novel Trait(s) subject of the Notice of Submission and the CFIA and Health Canada reserve all their rights under all the pertinent legislation that may be applicable. The CFIA and Health Canada in no way whatsoever waives any of their rights under any of the legislation they enforce or administer by way of the CFIA posting this Notice of Submission.

The Applicant is not obliged to provide any information. The Applicant submits information that it chooses to submit. The information that the Applicant voluntarily provides on this Notice of Submission is collected by the CFIA and Health Canada for the purpose of sharing information with the public. Personal Information will be protected under the provisions of the Privacy Act, and will be stored in Personal Information Bank CFIA PPU 125. Information, including personal information, may be accessible or protected as required under the provisions of the Access to Information Act.



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