The following is a cover letter sent on behalf of Dr. Don Huber, Professor Emeritus, Purdue University, to the EU and UK commissions at their request to provide a more detailed explanation of his January 17th letter to Secretary of Agriculture Tom Vilsack. His letter was sent in advance of the approval of Roundup Ready alfalfa requesting a delay of USDA approval and also for support for further research due to the discovery of a new pathogen that is prolific in Roundup Ready soybean and corn feed.
Dr. Huber's Letter:
Melba, Idaho 83641 USA
March 25, 2011
This cover letter is provided to explain the reasoning and concerns that were conveyed in a letter which I sent to Secretary of Agriculture, Thomas Vilsack on January 17, 2011 (Attachment 1). The letter was not intended for public distribution; however, the letter was ‘leaked’ and subsequently posted on the internet from which it soon became public knowledge world-wide. Once it was widely distributed, I gave permission for subsequent postings in order to keep it consistent. My busy meeting and travel schedule has delayed getting further information on this matter out publicly to the many individuals who have requested it. The scientific data on this newly recognized organism is being prepared for formal publication.
I wrote the letter to Secretary Vilsack for a very simple reason: we are experiencing a large number of problems in production agriculture in the U.S. that appear to be intensified and sometimes directly related to genetically engineered (GMO) crops, and/or the products they were engineered to tolerate – especially those related to glyphosate (the active chemical in Roundup® herbicide and generic versions of this herbicide). We have witnessed a deterioration in the plant health of corn, soybean, wheat and other crops recently with unexplained epidemics of sudden death syndrome of soybean (SDS), Goss’ wilt of corn, and take-all of small grain crops the last two years. At the same time, there has been an increasing frequency of previously unexplained animal (cattle, pig, horse, poultry) infertility and spontaneous abortions. These situations are threatening the economic viability of both crop and animal producers.
Incidence of high infertility and spontaneous abortions in the various animal species is becoming more common. Often, all previously known causes of these conditions can be ruled out as factors for these particular farm operations (Attachment 2). Detailed examination for the newly recognized organism has shown its presence in all of the cases examined to date. Koch’s postulates have been completed for animals to verify the cause/effect relationship with this newly culturable organism. A search for the source of animal infections revealed a high population of this newly discovered electron microscopic sized organism in soybean meal and corn products. The organism appears compatible, and probably synergistic, with other microorganisms such as Fusarium solani fsp. glycines, the cause of SDS of soybeans and also with gram positive bacteria. The organism also is in a very high population in Goss’ wilt infected corn caused by the gram positive bacterium Clavibacter michiganensis subsp. nebraskensis.
Although most corn hybrids have been genetically resistant to Goss’ wilt, preliminary research in 2010 demonstrated that the application of glyphosate herbicide, or the surfactant from glyphosate formulations, nullified this resistance and rendered them fully susceptible to this pathogen. This disease was commonly observed in many Midwestern U.S. fields planted to RR corn in 2009 and 2010, while adjacent non-GMO corn had very light to no infections in spite of the high inoculum present in no-till crop residues. The increased Goss’ wilt in 2010 was a major contributor to the estimated almost one billion bushels of corn ‘lost’ last year (based on USDA August estimated yields and actually harvested crop reported by USDA in January) in spite of generally good harvest conditions.
Increased severity of plant diseases after glyphosate is applied is well documented and, although rarely cited, the increased disease susceptibility is the herbicidal mode of action of glyphosate (Johal andRahe,1988, 1990; Johal and Huber, 2009; Schafer et al, 2009, 2010). The loss of disease resistance in Roundup Ready® sugar beets when glyphosate was applied prompted researchers at the USDA sugar beet laboratory to include a precautionary statement in their paper, e.g. “Precautions need to be taken when certain soil-borne diseases are present if weed management for sugar beet is to include post-emergence glyphosate treatments” (Larson et al, 2006).
The loss of genetic resistance in Roundup Ready® corn hybrids to Goss’ wilt (Clavibacter michiganensis subsp. nebraskensis) (Figs. 2, 3), synergistic relationship of the newly recognized electron microscopic organism causing infertility and abortions in animals with gram+ bacteria, and high populations of the new EM organism in RR corn leaves and silage creates a concern for the deregulation of Roundup Ready® alfalfa which is productive in many areas only because of its genetic resistance to bacterial wilt caused by Clavibacter michiganensis subsp. insidiosum. This disease could make alfalfa unprofitable for production and, if the EM organism is associated with it in alfalfa as it is in corn, also unsafe for animal feed and their products such as milk for human consumption. The loss of alfalfa, the United State’s most valuable forage crop and fourth most economically important crop, could strike a mortal blow to struggling dairy and beef operations.
Extensive research has shown that this potent tool for weed management, glyphosate, is also a strong immobilizer (chelator) of essential plant nutrients to impair nutrient uptake, translocation, and physiological efficiency at only a fraction of the labeled herbicidal rate (Ekers, Ozturk, Cakmak, Zobiole, Jolly et al., 2004). Glyphosate is a powerful biocide to harm beneficial soil organisms important for nutrient recycling, N-fixation, nutrient availability, and natural disease control (Kremer & Means, Zobiole et al, Dick et al) with a resultant increase in diseases of corn, soybeans (Fig. 3), wheat and other crops. The close relationship between mineral nutrition and disease severity is well documented (Datnoff et al, 2007). These activities can have deleterious effects on plant nutrition, disease susceptibility, and nutritional quality of the crop produced.
Deleterious effects of GM crops also are vividly demonstrated in reports from livestock producers in the U.S. Although some of these reports are anecdotal because of limited analytical techniques to verify the cause, some producers have been able to resume economical operations by changing feed sources to non-GMO crops. Replicated independent research is needed in this area, especially in light of the serious toxicological concerns raised recently that show potential human and animal toxicity from very low levels of residual glyphosate in food/feed that are many times lower than permitted in U.S. food and feed products (Seralini et al., 2011). The recent Indian Supreme Court’s independent analysis and Ruling that GMO egg plant posed a significant health risk to humans needs further evaluation in the U.S. (AgroNews, 2011).
I feel I would be totally irresponsible to ignore my own research and the vast amount of published research now available that support the concerns we are seeing in production agriculture, without bringing it to the attention of the Secretary of Agriculture with a request for him to initiate the much needed independent research. Many producers can’t wait an additional 3-10 years for someone to find the funds and neutral environment to conduct such critical research (Attachment 2. Entomologists letter to EPA).
Based on the scientific evidence currently accumulating, I do not believe it is in the best interests of the agricultural producer or consuming public for regulatory agencies to approve more GMO crops, particularly Roundup Ready® alfalfa and sugar beets, until independent research can establish their productivity when predisposed to potentially severe diseases, the irrelevance of the new EM organism, and their nutritional equivalency. In my letter, I asked the Secretary to allocate the necessary resources to do this, and requested that he exercise the utmost caution in deregulating these crops until such findings resolve the concerns expressed in the letter, if they do.
Don M. Huber Professor Emeritus, Purdue University 9322 Big Foot Road Melba, Idaho 83641 USA
AgroNews. 2011. India: Signs of food toxicity in GE eggplant. Scoop.co.nz 2011-1-18. [http://news.agropages.com/News/NewsDetail---3369.htm] Nib, 24 Jnuary 111.
Bellaloui, N., reddy, K.N., Zablotowicz, R.M., Abbas, H.K., and Abel, C.A. 2009. Effects of glyphosate application on seed iron and root ferric (III) reductase in soybean cultivars. J. Agric. Food Chem. 57:9569-9574.
Bott, S., Tesfamariam, T., Kania, A., Eman, B., Aslan, N., Roemheld, V., and Neumann, G. 2011, Phytotoxicity of glyphosate soil residues re-mobilise4d by phosphate fertilization. Plant Soil 315:2-11. DOI 10, 1007/s11104-010-06989-3.
Cakmak, I., Yazici, A., Tutus, Y., Ozturk, L. 2009. Glyphosate reduced seed and leaf concentrations of calcium, magnesium, manganese, and iron in non-glyphosate resistant soybean. European J. Agron. 31:114-119.
Datnoff, L.E., elmer, W.H., and Huber, D.M. 2007. Mineral Nutrition and Plant Disease. APS Press, St. Paul, Mn. 278. 278 pages.
Eker, S., Ozturk, L., Yazici, A., Erenoglu, B., Roemheld, V., and Cakmak, I. 2006. Foliar- applied glyphosate substantially reduced uptake and transport of iron and manganese in sunflower (Helianthus annuus L.) plants. J. Agric. Food Chem. 54:100019-10025.
Fernandez, M.R., Zentner, R.P., Basnyat, P., Gehl, D., Selles, F., and Huber, D.M. 2009. Glyphosate associations with cereal diseases caused by Fusarium spp. in the Canadian Prairies. European J. Agon. 31:133-143.
Johal, G.R. and Rahe, J.E. 1984. Effect of soilborne paltn-pathogenic fungi on the herbicidal action of glyphosate on bean seedlings. Phytopathology 74:950-955.
Johal, G.R. and Rahe, J.E. 1990. Role of phytoalexins in the suppression of resistance of Phaseolus vulgaris to Colletotrichum lindemuthianum by glyphosate. Canad. J. Plant Pathol. 12:225-235.
Johal, G.R. and Huber, D.M. 2009. Glyphosate effects on diseases of plants. European J. Agron. 31:144-152.
Kremer, R.J. and Means, N.E. 2009. Glyphosate and glyphosate-resistant crop interactions with rhizosphere microorganisms. European J. Agron. 31:153-161.
Larsen, R.L., Hill, A.L., Fenwick, A., Kniss, A.R., Hanson, L.E., and Miller, S.D. 2006. Influence of glyphosate on Rhizoctonia and Fusarium root rot in sugar beet. Pest Manag. Sci. 62:1182-1192.
Ozturk, L., Yazici, A., Eker, S., gokmen, O., roemheld, V., and Cakmak, I. 2008. Glyphosate inhibition of ferric reductase activity in iron deficient sunflower roots. New Phytol. 177:899-906.
Schafer, J.R., Westhoven, A.M., Kruger, G.R., Davis, V.M., Hallett, S.G., and Johnson, W.G. 2009. Effect of growth media on common lambsquarter and giant ragweed biotypes response to glyphosate. Proc. Northcentral Weed Sci. Soc. 64:102.
Schafer, J.R., Hallett, S.G., and jophnson, W.G. 2010. Role of soil-borne fungi in the response of giant ragweed (Ambrosia trifida) biotypes to glyphosate. Proc. Northcentral Weed Sci. Soc. 65:.
Seralini, G-E., Mesnage, R., Clair, E., Gress, S., de Vendomois, J.S., Cellier, D. 2011. Genetically modified crops safety assessments: present limits and possible improvements. Environ. Sci. Europe 23:10-20. http://www.enveurope.com/content/23/1/10
Tesfamariam, T., Bott, S., Cakmak, I., Roemheld, V., and Neumann, G. 2009. Glyphosate in the rhizosphere – role of waiting times and different glyphosate binding forms in soils for phytoxicity to non-target plants. European J. Agron. 31:126-132.
Yamada, T., Kremer, R.J., Camargo e Castro, P.R., and Wood, B.W. 2009. Glyphosate interactions with physiology, nutrition, and diseases of plants: Threat to agricultural sustainability? European J. Agron. 31:111-113.
Zobiole, L.H.S., Oliveira, R.S.Jr., Huber, D.M., Constantin, J., Castro, C., Oliveira, F.A., Oliveira, A. Jr. 2010. Glyphosate reduces shoot concentrations of mineral nutrients in glyphosate-resistant soybeans. Plant Soil 328:57-69.
Zobiole, L.H.S., Oliveira, R.S. Jr., Kremer, R.J., Constantin, J., Yamada, T., Castro, C., Oliveiro, F.A., and Oliveira, A. Jr. 2010. Effect of glyposate on symbiotic N2 fixation and nickel concentration in glyphosate-resistant soybeans. Applied Soil Ecol. 44:176-180.
Attachment 1: Letter to Secretary of Agriculture Thomas Vilsak CONFIDENTIAL and URGENT
The Honorable Thomas Vilsack United States Secretary of Agriculture
Dear Secretary Vilsack:
A team of senior plant and animal scientists have recently brought to my attention the discovery of an electron microscopic pathogen that appears to significantly impact the health of plants, animals, and probably human beings. Based on a review of the data, it is widespread, very serious, and is in much higher concentrations in Roundup Ready (RR) soybeans and corn— suggesting a link with the RR gene or more likely the presence of Roundup. This organism appears NEW to science!
This is highly sensitive information that could result in a collapse of US soy and corn export markets and significant disruption of domestic food and feed supplies. On the other hand, this new organism may already be responsible for significant harm (see below). My colleagues and I are therefore moving our investigation forward with speed and discretion, and seek assistance from the USDA and other entities to identify the pathogen’s source, prevalence, implications, and remedies.
We are informing the USDA of our findings at this early stage, specifically due to your pending decision regarding approval of RR alfalfa. Naturally, if either the RR gene or Roundup itself is a promoter or co-factor of this pathogen, then such approval could be a calamity. Based on the current evidence, the only reasonable action at this time would be to delay deregulation at least until sufficient data has exonerated the RR system, if it does.
For the past 40 years, I have been a scientist in the professional and military agencies that evaluate and prepare for natural and manmade biological threats, including germ warfare and disease outbreaks. Based on this experience, I believe the threat we are facing from this pathogen is unique and of a high risk status. In layman’s terms, it should be treated as an emergency.
A diverse set of researchers working on this problem have contributed various pieces of the puzzle, which together presents the following disturbing scenario:
Unique Physical Properties
This previously unknown organism is only visible under an electron microscope (36,000X), with an approximate size range equal to a medium size virus. It is able to reproduce and appears to be a micro-fungal-like organism. If so, it would be the first such micro-fungus ever identified. There is strong evidence that this infectious agent promotes diseases of both plants and mammals, which is very rare.
Pathogen Location and Concentration
It is found in high concentrations in Roundup Ready soybean meal and corn, distillers meal, fermentation feed products, pig stomach contents, and pig and cattle placentas.
Linked with Outbreaks of Plant Disease
The organism is prolific in plants infected with two pervasive diseases that are driving down yields and farmer income—sudden death syndrome (SDS) in soy, and Goss’ wilt in corn. The pathogen is also found in the fungal causative agent of SDS (Fusarium solani fsp glycines).
Implicated in Animal Reproductive Failure
Laboratory tests have confirmed the presence of this organism in a wide variety of livestock that have experienced spontaneous abortions and infertility. Preliminary results from ongoing research have also been able to reproduce abortions in a clinical setting.
The pathogen may explain the escalating frequency of infertility and spontaneous abortions over the past few years in US cattle, dairy, swine, and horse operations. These include recent reports of infertility rates in dairy heifers of over 20%, and spontaneous abortions in cattle as high as 45%.
For example, 450 of 1,000 pregnant heifers fed wheatlege experienced spontaneous abortions. Over the same period, another 1,000 heifers from the same herd that were raised on hay had no abortions. High concentrations of the pathogen were confirmed on the wheatlage, which likely had been under weed management using glyphosate.
In summary, because of the high titer of this new animal pathogen in Roundup Ready crops, and its association with plant and animal diseases that are reaching epidemic proportions, we request USDA’s participation in a multi-agency investigation, and an immediate moratorium on the deregulation of RR crops until the causal/predisposing relationship with glyphosate and/or RR plants can be ruled out as a threat to crop and animal production and human health.
It is urgent to examine whether the side-effects of glyphosate use may have facilitated the growth of this pathogen, or allowed it to cause greater harm to weakened plant and animal hosts. It is well-documented that glyphosate promotes soil pathogens and is already implicated with the increase of more than 40 plant diseases; it dismantles plant defenses by chelating vital nutrients; and it reduces the bioavailability of nutrients in feed, which in turn can cause animal disorders. To properly evaluate these factors, we request access to the relevant USDA data.
I have studied plant pathogens for more than 50 years. We are now seeing an unprecedented trend of increasing plant and animal diseases and disorders. This pathogen may be instrumental to understanding and solving this problem. It deserves immediate attention with significant resources to avoid a general collapse of our critical agricultural infrastructure.
COL (Ret.) Don M. Huber Emeritus Professor, Purdue University APS Coordinator, USDA National Plant Disease Recovery System (NPDRS)
Attachment 2. Letter from a Veterinarian
Hello, my name is ___________. I am a veterinarian in Michigan.
I am working with a sow herd that has had elevated death loss for over two years and very poor reproductive performance for the last 6-8 months. I have done extensive diagnostics (primarily at Iowa State) and can find nothing infectious that is routinely found to explain the problem.
I suspect there is a toxin involved; I have done extensive testing on liver, feed, and water but can find no evidence of those compounds either. We have had a few individuals mention that the use of GMO crops could be contributing to these problems.
The producer recently saw your article to the secretary of agriculture and forwarded it to me. We are very intrigued by the organism you mention. Could you tell me if any laboratory is looking for this agent? How do we go about finding it? We are at the end of our rope and cannot figure this out. Any help you can give us would be greatly appreciated.
Attachment 3. Letter from 26 University Entomologists to EPA
Public Submission: EPA-HQ-OPP-2008-0836-0043. Docket EPA-HQ-OPP-2008-0836 Docket Title Evaluation of the Resistance Risks from Using a Seed Mix Refuge with Pioneer's
Optimum AcreMax 1 Corn Rootworm-Protected Corn Document EPA-HQ-OPP-2008-0836-0001; Public Submission EPA-HQ-OPP-2008-0836-0043
Public Submission Title Anonymous public comment Receipt Date 02/09/2009 Doc. Legacy ID EPA-HQ-OPP-2008-0836-0032(0900006480849377) Track No. 8084de39
The following statement has been submitted by 26 leading corn insect scientists working at public research institutions located in 16 corn producing states. All of the scientists have been active participants of the Regional Research Project NCCC-46 "Development, Optimization, and Delivery of Management Strategies for Rootworms and Other Below-ground Insect Pests of Maize" and/or related projects with corn insect pests. The statement may be applicable to all EPA decisions on PIPs, not just for the current SAP. It should not be interpreted that the actions and opinions of these 26 scientists represent those of the entire group
of scientists participating in NCCC-46. The names of the scientists have been withheld from the public docket because virtually all of us require cooperation from industry at some level to conduct our research.
"Technology/stewardship agreements required for the purchase of genetically modified seed explicitly prohibit research. These agreements inhibit public scientists from pursuing their mandated role on behalf of the public good unless the research is approved by industry. As a result of restricted access, no truly independent research can be legally conducted on many critical questions regarding the technology, its performance, its management implications, IRM, and its interactions with insect biology. Consequently, data flowing to an EPA Scientific Advisory Panel from the public sector is unduly limited."