Comment from Claudia L Woodward-Rice

The patent application US2005/0039235 A1 Methods for the production of insulin in plants describes the genetic modifications that allow high level production of human insulin in plants. Animal feeding tests evaluating the toxicity of the gene and its proteins were not included with the EA. According to the USAD-APHIS draft environment assessment the threatened species in the test area include bald eagle, pygmy rabbit, Columbian white tailed deer and grey wolf. The plant species include Spalding's catch fly and Ladies' tresses. Pygmy rabbits are the most threatened specie- the Columbia pygmy rabbit feeds mainly on sagebrush. Their number may be as low as 30 or less. There is evidence ignored by APHIS, that shows the ingested pro insulin from transgenic safflower is active after oral ingestion. The disruption of the habitat of threatened species such as the pygmy rabbit by human activities and transportation is likely to drive the treasured animals to extinction. APHIS displayed a cavalier disregard for the treasured species and appears to have ignored studies that did not support their conclusions. There is at least one report showing transgenic pro insulin can effectively reduce blood glucose in rats. The APHIS ER presumes that human pro insulin will be degraded too rapidly to be active when it is ingested by animals but reports show that is not entirely the case, and functional peptides were found to enhance intestinal absorption of insulin. Seed debris may produce dust containing human pro insulin and it is worth noting that inhaled insulin is an available option for human therapy. All these conditions demonstrate the dangers inherent in open air testing of such a genetically modified plant, especially since it is being done in a food crop! One frequently wonders if if the Monsanto-USDA connection is essentially a suicide pact. Continued risk taking is bound to produce a catastrophe.