July 1, 1996 EP A/600/A-96/096 Assessing Risks from GMOs to Ecosystems and Human Health R.J. Seidleri*, L.S. Watrudi, and S.E. Georges 1 U.S. Environmental Protection Agency, Office of Research and Development National Health and Environmental Effects Research Laboratory Western Ecology Division 200 S.W. 35th Street, Corvallis, OR. 97330 (USA) 2 U.S. Environmental Protection Agency, Office of Research and Development National Health and Environmental Effects Research Laboratory Environmental Carcinogenesis Division Mail Drop 68 Research Triangle Park, N.C. 27711 (USA) Corresponding author (541) 754-4708, FAX (541) 754-4799, E-Mail seidler@mail.cor.epa.gov Key Words: genetically engineered organism, risk assessment, health effects, environmental effects This document has »been subjected to the Agency's peer and administrative review, and It has been approved for publication as an EPA document. Mention of trade names or commercial products does not constitute endorsement or recommendation for use. ------- "Assessing Risks from GMOs to Ecosystems and Human Health" I. Introduction Since the 1970s, scientists have been altering directly significantly the genetic makeup of living creatures (Tzotzos, 1995). Techniques in molecular biology have made it possible to incorporate genes from one organism into virtually any other organism's genetic composition to create a broad array of unique life forms. These unique organisms may have traditional or totally new uses for applications ranging from agriculture, food and beverage and pharmaceutical production, to environmental clean up and energy production. Through this technology industry anticipates promises of unique economic opportunities from patented "new" life forms. These rapid technological developments in molecular biotechnology are forcing society to think about new concepts in biology and to contemplate the potential effects that recombinant DNA technology can have on ecosystems and on human health (Levin, et al., 1987; Levin and Strauss, 1990; Regal, 1990). Questions about proprietary rights to novel germplasm, cloned genes, and the patenting of "new" life forms have also been raised. 9 Genetically modified organisms (GMOs) have already been released experimentally into the environment. Essentially these releases have been 2 ------- small scale tests, designed to primarily examine product efficacy, not usually to evaluate potential environmental risks. Some negative environmental perturbations have been noted in some studies where risk assessment has been an experimental objective. However, since the reported effects were limited in scale and communicated largely through technical channels, few adverse public reactions to these results have been noted (Leopold, 1995). It has been over 20 years since the first recombinant microorganism was constructed and probably half as many years since they were suggested for use in the environment. There have already been more than 1,000 applications to allow the testing of genetically engineered organisms, most of which have or will be released in the U. S. (Mellon and Rissler, 1993). Once released, interactions with biotic and abiotic factors can disperse microbial agents over considerable distances(Seidler and Hern, 1988; Lighthart and Kim, 1989; Seidler, et al., 1994) and a desire for properly conducted risk assessments is supported by most who are involved with this technology . The widespread environmental experimentation with GMOs raises important questions. Can the risks of GMOs be assessed without actually releasing the agents directly into the natural environment? Can the impacts be anticipated and is knowledge of ecology sufficient to predict with confidence th£ fate and survival of a microbial agent and how it might interact with ecosystems and humans? Concern has been expressed by numerous scientists regarding the release of GMOs before such risks 3 ------- are understood (Halvorsen, Pramer, and Rogul, 1985; Levin and Strauss, 1990; Sharpies, 1990). Clearly, the possible risks that GMOs may pose to the natural environment must be estimated and assessed before decisions are made as to their release. In order to ensure public health and environmental safety, the United States Government mandated that release of genetically engineered microorganisms be regulated by Federal Register statutes (1986). The US Environmental Protection Agency regulates microbial pesticides and microbial "chemicals" through Subdivision M (Microbial Pesticides) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Toxic Substances Control Act (TSCA). In the European community, release of genetically engineered microorganisms and the microbial plant protection products are regulated through Directive 90/220/EEC and Directive 91/414/EEC respectively. Under both of these Directives, risk assessments of health and environmental effects of the products are determined. In response to the diversity of product opportunities as well as risk assessment concerns raised through many organizations and individuals around the world, a massive R&D effort is underway in Europe to address risk assessment issues. Designated the "biotechnology programme", the research is funded through the European Commission and designated as part of the fourth European Community research and technological « development framework program for 1994-1998. Currently there are about 528 laboratories from every Union country sharing a budget of ECU 4 ------- 73 million. Further details of this program can be accessed through the internet via the URL posting; http://www.cec.Iu/en/comm/dg12/networks.html. The bases for general risk assessment of GMOs are understandably different from those associated with chemicals. GMOs are living organisms and therefore, unlike chemicals that may become diluted, GMOs have the potential to disperse to new habitats, colonize those sites, and multiply. Their novel activities including the production of metabolic products, enzymes, and toxins, will occur as long as the GMOs remain metabolically active. Once established, living organisms cannot be recalled. The last twelve years has seen a new era of environmental research devoted in part to the risk assessment issues associated with the environmental release of GMOs (Bourquin and Seidler, 1986; Levin, et at., 1987). This research seemed justified considering the anticipated widespread development and application of GMOs and their multitude of capabilities. An understanding of basic ecological and evolutionary concepts as to why organisms may survive or flourish in natural ecosystems have changed comp?red to only 15-20 years ago (Regal, 1990). Many of the risk assessment decisions on safety issues will depend upon whether and how one weighs new concepts within ecology and evolution relative to older theories. For example, conventional wisdom has it that if one engineered in a new trait, selection by the environment would return the organisms to their original state. Exotic species introductions mostly fail to establish 5 ------- in nature because the new conditions are not conducive to their survival (Williamson, 1994). However, the engineering of an already established host begins with an ecological advantage. Genetic engineering may also enhance that competitive advantage. When exotic species go out of control it is not only because they have escaped natural constraints, but because they sometimes find new ecological opportunities (Regal, 1990). A thorough discussion of the ecological concepts involved in biological introductions excluding GMOs along with reasons for their success or lack of success in establishment is offered in this Handbook in the chapter by Simberloff and Alexander. Most of the concepts discussed in that chapter are probably directly applicable to GMOs as well. The purposes of this chapter are to describe and characterize primarily genetically engineered microorganisms and the relevant tools used for their risk assessment, provide examples of observed and possible environmental effects induced by GMOs, summarize methods available for detecting effects (both human and environmental) , and provide discussions on possible hazards associated with their repeated, large scale environmental releases that is anticipated in the near future. Many unknowns still exist about the environmental and human health significance of r«sks from GMOs despite approximately 11 years of research. However, much has also been learned about how to experimentally detect possible risks and the nature of those risks have now been documented; both subjects are topics to be discussed in this chapter of the Handbook. The sections below will (a) illustrate specific examples of genetically engineered microorganisms; (b) define the risk 6 ------- associated issues; (c) report known ecological and health effects of GMOs; and (d) highlight continuing and future research needs for the use of GMOs. II. Examples of GMO products IIA. Bacteria With the advent of modern molecular methods, the identification, isolation and movement of genes from one organism to another, even between species or taxa which may traditionally have breeding barriers, has been greatly facilitated. Consequently, the variety of microbes that can produce novel products or have novel and useful activities is increasing dramatically. The scope of microbial activities being developed ranges from crop protection and environmental restoration, to food, beverage, pharmaceutical and specialty product production (Harlander 1992; Edgington 1994; Valigra 1994; Watrud & Seidler 1996). The examples given below will illustrate a variety of specific applications for genetically modified bacteria developed for either environmental or contained applications. IIA1. Crop protection (pest control for Insects, diseases) 9 Intentional selection and development of bacteria intended for large scale environmental release have primarily been made for agricultural purposes, 7 ------- particularly for insect control. Between 1948 and 1995, twenty-five bacterial products were registered for use in the United States as microbial pesticides (Schneider personal communication). Eighteen of those registrations occurred after 1992. In part, it has been this increased interest in microbials for pest control, that has led to the recent creation of a Division of Biological Pesticides within the United States Environmental Protection Agency. The most widely used bacterial species for biological control of insect pests is Bacillus thuririgiensis subsp. kurstaki (B. t. kurstaki), which has a high degree of specificity for lepidopteran insects. The active pesticidal ingredients in B. t. kurstaki and in the related species B. t. subsp. tenebrionis, which has a high degree of activity against certain coleopteran insect pests, are proteins (McPherson et al. 1988; Hofte & Whiteley, 1989). Using both classical breeding and recombinant methods, geneticists have tried to create strains that express higher levels of one or both of the desired insecticidal protein activities (Gawron-Burke & Baum 1991; Bosch et al. 1994). Several engineered strains of Bacillus thuringiensis have recently been registered (Bill Schneider, personal communication). Additional Bacillus species registered in the United States for the control of coleopteran insect pests include B. popilliae and B. lentimorbus (Schneider personal communication). In addition to efforts to improve microbial formulations of Bacillus species, pesticidal genes isolated from Bacillus species have been or are being cloned into a number of plant species, including giajor food and fiber crops such as corn, cotton, potatoes and woody species (reviewed in Watrud et al. 1996). A concern resulting from the anticipated millions of acres to be planted in crops 8 ------- expressing B. t. proteins, is an increase in the rate of development of resistance in insect pests (Tabashnik 1994). On the human health side, a potential concern is whether allergenic reactions may develop in people exposed to higher levels of the insecticidal proteins, due to increased environmental and dietary exposures. Non-target effects of microbial forms of B. t. kurstaki on insects and on microbial biota in soil have recently been reviewed (Watrud & Seidler, 1996). Bacillus species and Pseudomonas species have each been proposed and evaluated for use as biological control agents for Rhizoctonia and Pythium, fungi which cause damping off diseases of seedlings (Weller 1988; Whipps 1992; Lumsden et al. 1995). Bacterial treatments for disease control have been evaluated as seed treatments, as root drenches for transplants, and as dry or liquid soil treatments. Although short term ecological and toxicological effects and other safety considerations of microbial pesticides typically have been addressed (Levin 1995), studies on long term non-target effects of bacterial pesticides have often been limited (Watrud & Seidler, 1996). Both fungi and bacteria pathogenic or phytotoxic to specific types of plants have been proposed for weed control. Dacterial genera reported to have herbicidal activity include isolates of Streptomyces, Bacillus and Pseudomonas (Charudattan 1990; Hoagland1990; Stonard & Miller- Wideman 1995).' ¥Ks with the fungal biocontrol agents which are described below, a major concern of using biocontrol agents that are themselves pathogens, is their actual degree of host specificity; i. e., will 9 ------- non-target crop or native species also be affected? Increases in the competitiveness of existing plant pathogens due to the acquisition of traits such as tolerance to pesticides, heavy metals or temperature extremes, by genetic recombination, are also of potential concern. IIA2. Plant growth promoting biofertilizers /rhizobacteria Use of commercial inocula of nitrogen fixing strains of Rhizobium or Bradyrhizobium for seed treatment of legumes has become a standard agronomic practice. Attempts have also been made to boost the nitrogen fixing capacity of the inocula by the use of recombinant methods (Paau 1991; Hall 1995). For graminaceous species such as barley and wheat, non-symbiotic nitrogen fixers (Azospirillum lipoferum, A. brasiliensis, A. chroococcum), have been tested in greenhouses and in the field for a number of years, often yielding positive effects on plant growth and yield, particularly in warmer climates (Dobereiner et al. 1988; Bhattari & Hess, 1993; Di Ciocco & Rodriquez-Caceres 1994; Zaady & Perevolotsky 1994). Effects of environmental conditions on efficacy of inocula have also been studied; however, ecological studies on non-target effects of Azospirillum inocula have not been reported. Several bacterial preparations (P. cepacia, P. flourescens, E$. subtilis), have been examined as seed treatments which may permit or enhance plant growth by inhibiting damping off fungi (Weller 1988; Whipps 1992; Lumsden et at. 1995). The distinction between biological control agents used for controlling soil-borne plant diseases and plant growth promoting 1 0 ------- rhizobacteria, may be largely a semantic one. To date, there are no registrations in the United States under TSCA, for plant growth promoting bacteria per se. However, approximately one fourth of the bacteria registered as microbial pesticides in the U. S. have plant diseases as their targeted pests. IIA3. Biomass conversion agents In addition to starch or sugar crops such as corn and sugarcane, lignocellulosic wastes also can be used as substrates for the production of ethanol by fermentation. Pre-treated mechanically and chemically, e.g., by milling and acid or alkaline hydrolysis, complex wastes then can be subjected to fermentation. Traditional sources of lignocellulosic biomass are the by-products of logging, wood and paper processing operations. Short rotation woody or herbaceous species such as poplars and switchgrass and agricultural residues including corn stover, seed hulls, straws and peels are also potential commercial sources of lignocellulose. Several species of engineered bacteria (Klebsiella planticola, Klebsiella oxytoca, Zymomonas mobilis and Streptomyces lividans), have each been considered for production of ethanol from agricultural residues or for degradation of lignocellulosic residues from paper milling operations (Trotter 1990; Helsot 1990; McCarthy & Williams, 1992; Wood & Ingram, 1992; Crawford et al. 1993; Sprenger 1993). Anaerobic digestion of lignocellulosic and municipal wastes also has been evaluated as a means of producing energy in the form of methane (Wyman & Goodman 1993). The feasibility of producing lipids as a result of metabolism of sugars 11 ------- produced by photosynthetic activities of marine micro-algae such as diatoms also has been proposed (De La Noue & De Pauw 1988; Wyman & Goodman 1993). Specialty chemical production (e .g., for solvents such as acetone), by engineered isolates of Clostridium acetobutylicum, also has been studied (Mermelstein et al. 1993). IIA4. Bioremediation and Mining Applications A number of isolates of Pseudomonas species (P. putida, Burkholderia cepacia) have been studied biochemically, genetically and to a lesser degree ecologically, for their potential use and non-target effects in the remediation of polluted soils, sediments and surface and ground waters (Mulbry & Kearney 1991; Fan & Scow, 1993; Krumme et al. 1994; Edgington 1994; Ramos et al. 1994). Laboratory selection and genetic engineering for customized degradation of given aromatic compounds by individual isolates has been actively pursued for a number of years (Singleton 1994; Daubaras et al. 1995). However, intentional environmental applications of engineered organisms for bioremediation purposes have been few, limited in part by environmental and public opinion concerns. Those issues, along with cost considerations, often have led to management of both marine and terrestrial spills by physical or chemical methods which enhance desired indigenous microbial activities. These methods include the use of absorbents (straw or * sawdust or biopolymers), agitation to increase aeration and oxidation, pH modification, and addition of fertilizers (organic and inorganic) and organic substrates such as molasses or starch (King et al. 1992; Rouchard 12 ------- et al. 1993). Less frequently, non-engineered inocula have been added to achieve the desired degradation and bio-transformations. In 1990, a polyaromatic hydrocarbon degrading strain of Pseudomonas fluorescens, HK44, containing an engineered bioluminescent reporter plasmid for napthalene catabolism (King, et a!., 1990) was approved for field testing in the U.S., under TSCA (Phil Sayre, personal communication). To date, however, engineered inocula have been used primarily In contained laboratory facilities or microcosms, or in bioreactors that have been brought to contaminated field sites or to centralized treatment centers. Recently, progress has been reported in the development of transformation systems for Thiobacillus and Leptospirillum, genera which may prove to be useful in management of leachates from mining operations (Rawlings & Silver 1995). Other proposed applications for bacteria in mining include the bioconcentration of valuable metals and for the detoxification of waste streams by the adsorption or complexation of heavy metals by microorganisms (Francis 1990; Wales & Sagar 1990; Sahoo et al. 1992; Volesky & Holan 1995). Potential roles for using microbially based processes to desulfurize coal with isolates of Thiobacillus, Leptospirillum or Rhodococcus have also been proposed (Merretig et al. 1989; Kilband & Jackowski 1992; Mannivannan et al. 1994). HAS. Food biotechnology /Specialty products I Historically, the longest term de facto or intentional applications of bacterial activities by humans have been the use of fermented foods. 13 ------- Traditional and ethnic foods such as sausages and sauerkraut, soy sauce and miso, salami and pepperoni, yogurt, cheese, and buttermilk, have a long history of consumption world-wide. In addition to creating characteristic flavors, aromas or textures, the microbial activities often have enhanced the storage life of the meats, milk, fruit and grains which have served as the substrates for the bacterial activities. Dairy products produced as a result of controlled fermentations with known bacterial inocula include yogurt, buttermilk, sour cream, and Swiss cheese (Harlander 1992). As the sciences of microbiology, biochemistry and genetics have advanced, the ability to select, improve and create strains with desired activities has also increased. Specific examples of the applications of biotechnology to the dairy industry include strain improvement and development of DNA based diagnostics for both inocula and contaminants in foods (Ramos and Harlander 1990; Mc Intyre & Harlander 1993). Additional useful products resulting from bacterial fermentations include organic acids such as citric acid which can be used as a food preservative or flavoring agent, vitamins, and amino acids such as lysine and methionine, which are used as food or feed supplements. Organic acids and amino acids produced as a result of fermentations also may serve as substrates for subsequent modifications, e. g., the chemical combination of microbially produced phenylalanine with aspartic acid, to produce the sweetener, aspartame (De Boer & Dijkuizen, 1994). Enzymes used in food processing or detergent industries (i. e., proteases, invertases, lipases fand amylases), also may be derived from bacterial fermentations (Harlander 1992). In addition to the production of fermented foods, bacterial activities have also been utilized to produce 14 ------- food ingredients ranging from thickeners, sugars, and vitamins, to pigments, flavors, and amino acids (Harlander 1992; Gableman 1994). Enzymes derived from bacteria (e. g., amylase, glucose isomerase, pullulanase), are used in food and beverage processing for starch liquefaction, high fructose corn syrup production and in beer production. Biotechnological methods also are being used to select and modify strains of Lactobacillus to improve the digestibility and preservation of silage (Flores 1991; Wallace 1994). Most examples given above have been taken from processes that generally have been carried out indoors, in vats or fermentors. As the use of recombinant strains increases, some concerns may arise as to the health or environmental effects of those strains, or novel products produced by them, in the event of spills or leaks. Potential adverse effects include short term fish kills, resulting from lowered oxygen levels in contaminated lakes or streams. Additional concerns include health risks to susceptible individuals who may be immunocompromised or allergic to recombinant proteins expressed in the released microbes. IIA6. Pharmaceuticals Many of the antibiotics in common use today are fermentation products or synthetic derivatives of bacterial metabolites produced during closely controlled fermentations. Prominent among the medically useful bacterial species that have served as sources of numerous commercial antibiotics are the genera Streptomyces, Actinomyces, and Bacillus. The well known 15 ------- antibiotics, streptomycin, actinomycin and bacitracin are produced respectively by Streptomyces, Actinomyces and Bacillus (Glasby, 1992). As techniques for transforming key antibiotic producing species of microbes have become available, cloning of genes controlling metabolic pathways involved in antibiotic synthesis have permitted the development of strains which may serve as the source of new, novel and useful antibiotics (Malpartida & Hopwood 1992; Hopwood 1993; McDaniei et al. 1993; Valigra 1994; Bedford et al. 1995; Kakinuma et al. 1995). The availability of technologies to produce new types of antibiotic compounds is becoming increasingly important as new antibiotic resistant strains of human and veterinary pathogens continue to develop and spread in clinical and outdoor environments. In addition to production of novel bacterial compounds in bacterial hosts well suited for growth in fermentors, recombinant technologies are being applied to develop microbially derived vectors to optimize production of mammalian compounds in bacteria, bacterial compounds in plant cell cultures, and monoclonal antibodies in animal cell lines. Recombinant pharmaceuticals used for human and veterinary growth enhancement, metabolic regulation or for therapeutic purposes, include human and animal (bovine and porcine) growth hormones, insulin, inteferons, blood clotting factors, tissue plasminogen activator, and vaccines (Thayer 1992, 1994; Ladisch & Kohlman, 1992; Borman 1994; Munn 1994). One concern of biotechnology applications for production of pharmaceuticals is allergenicity of susceptible individuals to recombinant proteins. Environmental concerns resulting from pharmaceutical applications of biotechnology are limited primarily to events resulting from spills or leaks, which might result in fish kills or other non-target 16 ------- effects. IIB. Fungi IIB1. Crop protection Twelve of the forty-five microbial pest control agents registered in the United States are fungi. The agents include Beauveria and Metarrhizium, used for the control of insects, Colletotrichum, used to control the weed joint vetch, in rice, Cronartium, used to control water hyacinths, and Puccinia, used for control of nutsedge. Several fungi (Trichoderma and Gliocladium), are registered for the control of control of the plant pathogenic fungi Pythium and Rhizoctonia., which cause damping off diseases of seedlings. In France and Italy, hypovirulent strains of the causal organism of chestnut blight, En doth ia (Hyponectria) parasitica, have been successfully used in the field, to treat the disease (MacDonald & Fulbright, 1991; Nuss 1992). Some of the major ecological concerns which arise with the increasing use of biological agents include non- target effects of the released agents on beneficial organisms (James and Lighthart 1994; Watrud & Seidler 1996), and the potential for increased host range or competitiveness, resulting from genetic recombination between released and indigenous strains (Cisaref al. 1994). Health concerns center largely on potential allergenicity of the inocula to sensitive individuals. 17 ------- IIB2. Mycorrhizae Each of the major classes of mycorrhizai fungi can enhance inorganic nutrient uptake in host plants and help alleviate the effects of stressors ranging from drought, disease organisms, and heavy metals to agricultural chemicals (Gildon & Tinker, 1983; Heggo & Angle, 1990; Hetrick et al. 1994). Among the three major classes of mycorrhizae, /. e., the ectomycorrhizal fungi, the ericoid mycorrhizai fungi, and the vesicular- arbuscular mycorrhizai (VAM) fungi, laboratory culture has become routine primarily only for members of the ectomycorrhizal group. Accordingly, it is the group of ectomycorrhizal fungi which includes the basidiomycete genera Pisolithus and Laccaria, and the ascomycete genera Tuber and Morchella, which has received the most commercial attention in terms of inoculum production and genetic improvement. Basidiomycete ectomycorrhizal inocula are used to inoculate conifer species used in restoration of areas damaged by mining and smelting operations. Among the ericoid mycorrhizai fungi that typically form symbiotic associations with ericaceous plants, only two genera (Hymenoscyphus and Oidiodendrori), can be routinely cultured in the laboratory (Linderman, personal communication). The vesicular- arbuscular mycorrhizai (VAM) fungi, which include the phycomycetous genera Glomus and Gigaspora, can associate with most herbaceous species, and at some life stages, with some woody species as well. However, these fungi evade extended axenic culture in the laboratory. Accordingly the VAM fungi routinely are maintained by being grown in 18 ------- association with the roots of host plants such as grasses, onions or legumes. Most biotechnological work to date with mycorrhizal fungi has focused on the development of molecular probes to identify effective strains, particularly of ectomycorrhizal and VAM fungi (Simon et al. 1993; Lanfranco et al. 1995; Paolocci et al. 1995; Tommerup et al. 1995). As axenic culture methods become improved or available for the various types of mycorrhizal fungi, the potential to transform mycorrhizal fungi to select or create more competitive strains is expected to increase (Hall 1995). However, given the relative lack of specificity of ectomycorrhizal fungi among conifers and of VAM fungi among herbaceous and some hardwood species, the ability to mitigate the spread of (undesired) strains, which may displace or outcompete desired strains, could be environmentally or economically problematic. IIB3. Biomass conversion Yeasts, especially Saccharomyces spp., are the traditional organisms of choice for production of ethanol from fruits and grains, potatoes and sugarcane. Other yeast species, including Yarrowia isolates, also have been evaluated for industrial purposes, including the biotransformation of lipids (Helsot 1990). Isolates of the filamentous fungus Trichoderma, noted above as a biological agent for plant disease control and producer of enzymes, also have been proposed for use in the conversion of lignocellulosic wastes for fuel production, and for the treatment of cotton-based textiles. This industrial interest in Trichoderma accordingly has resulted in research on the molecular biology and safety 19 ------- of the organism (Pentiila et al. 1991; Nevalainen et al. 1994). The oyster mushroom Pleurotous ostreatus, which is edible, also has been evaluated as a commercial candidate to degrade ligninocellulosic wastes (Kerem & Hadar1995). In addition to their degradative activities, bacteria and fungi may also serve in biomass conversions, biopulping or biobleaching, or as pollution prevention agents by minimizing accumulation of toxic metabolites. However, the possibility of toxic metabolite production by the biomass conversion or remediating agents also needs to be considered in risk evaluations. IIB4. Bioremediation Utilization of fungal activities in bioremediation may occur by management of indigenous inocula, or by addition of exogenous inocula. For example, composting may effect a remediation due to activities of indigenous flora on straw or sawdust added to polluted soils. The white rot fungus Phanaerochaete chrysosporium, has been reported to degrade a number or compounds, including 2, 4, 5,-trichlorophenol (2,4,5-T), the BTEX complex (benzene, toluene, ethylbenzene and xylene), and pentachlorophenol (PCP) (Joshi & Gold, 1993; Yadav & Reddy, 1993). Additional filamentous fungi evaluated as polyaromatic hydrocarbon bioremediating agents include Acremonium and Curwinghamella (Pothuluri et al. 1995). Filamentous fungi such as Rhizopus, the common bread mold, and Absidia, each have been proposed for use in biosorption of heavy metals for detoxification of waste streams (Volesky & Holan, 1995). As 20 ------- transformation methods and vectors for fungal systems become more available, increased efforts in engineering industrial strains is anticipated. One concern associated with the environmental release of degradative fungal strains, many of which may be plant pathogens or saprophytes in nature, is the development of more competitive pathogens as the result of genetic recombination with indigenous pathogens or other compatible strains. Another concern is the potential for adverse effects on the quality and storage life of plant-based food and fiber crops. Allergenic reactions in sensitive individuals either to the fungi or to recombinant proteins produced by them, also are of concern. IIB5. Food/Beverage Industries Whether added intentionally as pure cultures, or inadvertently as indigenous flora on fruits and grains, historically yeasts (especially Saccharomyces species) have been used to produce alcoholic beers, ales and wines. In more recent times, genetic selection and improvement of yeasts have been explored to more consistently attain desired aromas and flavors (Rank & Xiao, 1991; Colagrande et al. 1994). They are also being used to produce light beers, with reduced starch, sugar and calorie contents, and to help regulate the level of ethanol in final products. The composition of high fructose com syrups used in non-alcoholic beverages such as carbonated sodas and juices and in products such as jams, jellies, and pancake syrups, also can be adjusted by the use of genetically improved strains or enzymes such as invertases, amylases, glucose isomerases, pullanases, derived from the selected strains (Harlander 21 ------- 1992). IIB6. Human and Veterinary Pharmaceuticals Prominent among the strains of filamentous fungi which have served as sources of antibiotics or as models for chemical synthesis are the genera Perticillium and Cephalosporium, known for their synthesis of the broadly used penicillins and cephalosporins (Weil et al. 1995). Strains of the phycomycete Rhizopus, have served as gene sources, precursors or models for the production of steroids such as the cortisones used as anti- inflammatory agents and in the manufacture of steroid hormones used in birth control pills (Breskvar et al. 1991; Vidyarthi & Nagar 1994). Genetic engineering of yeasts as hosts for the production of heterologous proteins, has also been explored (Buckholz & Gleeson 1991). IIC. Viruses Seven of the forty-five microbial pest control agents currently registered with the United States Environmental Protection Agency are viruses used to control lepidopteran insect pests of forest and agronomic species. Efforts to select and modify viral insecticides, include using genetic engineering to broaden the host range of viruses (Vlak 1993). Recent approvals for field testing in the United States for engineered microbial « pesticides include recombinant insecticidal baculoviruses which express insect specific toxin genes derived from scorpions (Bill Schneider, personal communication). With the advent of genetic engineering of higher 22 ------- plants, viral elements including the genes encoding viral coat proteins of plant pathogens, have been cloned into a number of food crops including tomatoes, potatoes and cucurbit species. Other viral elements such as the cauliflower mosaic virus (CaMV35S) promoter, also have been instrumental in obtaining or optimizing expression of diverse genes in engineered plants (Sanders et al. 1987). Engineered plants expressing viral coat proteins have been demonstrated to confer protection to one or more types of viruses, particularly the types which served as the source of the viral coat proteins (reviewed in Watrud et al. 1996). In addition to plant protection by expression of viral genes (coat proteins, ribozymes, viral satellite RNAs), some plants may be protected from certain viruses by treatment with either closely related viral strains or with avirulent strains. The concept of cross protection using intact viruses has been used to control tristeza, an aphid transmitted virus disease of citrus crops (Fulton 1986). Aphids exposed to avirulent strains of the virus are used to transmit the avirulent strains to citrus trees, thereby minimizing the effects of virulent viral strains on the citrus trees. Other crops for which the cross protection approach of using viral inocula to protect crops against viral diseases is being evaluated include cacao (for swollen shoot), papaya (for ringspot), avocado (for sun blotch), and stone and pome fruits, such as peaches and apples (Whipps 1992). Hypovirulent strains of the fungal causal agent of chestnut blight [Cryphonectria (Endothia) parasitica)] reported to have been successfully used to control the disease, have consistently shown a correlation with the presence of virus-like double stranded RNAs (MacDonald & Fulbright 1991; Nuss 1992). An engineered hypovirulent strain of Cryphonectria received approval for 23 ------- field testing in the U.S. in 1994 (Jane Rissler, personal communication). Mammalian pathogens including poliomyelitis, influenza and sindbai viruses, currently are being evaluated as expression vectors in animal cell systems, for the production of heterologous proteins (Schlesinger 1995). The use of transgenic plants as factories to produce viral components such as coat proteins or other antibodies, which might be used in production of vaccines for human or veterinary applications, also has been proposed (Hiatt et al, 1989). Environmental concerns which emanate from the use of virus-resistant transgenic plants include the selection for novel, more competitive viruses, potentially with broader host range arising as the result of genetic recombination. Another concern related to the use of transgenic virus-resistant plants, is that they may serve as reservoirs of inoculum for viral transmission via biological or mechanical means, to non-protected plants. Allergenicity and pathogenicity to sensitive individuals may cause potential health concerns following exposure to viral expression systems and expression of foreign proteins. III. Issues to Consider in Conducting Risk Assessments of GMOs. A document written in 1984 (Bourquin and Seidler, 1986) developed and guided the earliest strategies to provide methods for conducting risk assessments of GMOs released to the environment. In that report, research plans were developed that addressed the need for increased research in microbfal ecology in order to provide knowledge on how to conduct GMO environmental risk assessments. The focus of basic research needed to conduct appropriate risk assessments is summarized as follows: 24 ------- • Methods are needed to detect, identify, and enumerate released GMOs •Methods are needed to determine fate and transport of the GMO * Genetic stability, i.e., propensity for gene transfer must be assessed •Hazard Assessments (pathogenicity to non-target spp. including humans and disruption of environmental processes) must be thoroughly investigated *A means to mitigate possible effects would be prudent. Environmental risk of GMOs has been described as a function of the exposure and the hazard posed by the GMO (Bourquin and Seidler, 1986; Levin and Strauss 1990). This relationship has helped conceptually to develop strategies for identifying relevant research needs to address the ecological concerns of releasing GMOs to the environment. Thus, exposure is a general function of organism survival and multiplication (cell density), which in turn influences GMO transport in the environment. Hazard is a function of ecological effects including competitiveness and metabolic activities that perturb the habitat, as well as pathogenicity, virulence, toxicity, and allergenicity. Therefore it is essential to understand the fundamental ecology and physiology of the organism to be released and the basic character of the release environment in order to address questions concerning risk assessment of the GMO (U.S. Environmental Protection Agency, 1992). These evaluations to date largely have been conducted on a case-by-case basis because most products are unique and previously have not been encountered by regulators, ecologists, and the environment. 25 ------- In order to conduct a risk assessment of a GMO, information is needed on at least five technical issues that comprise the exposure and hazard subcomponents for a microorganism (Bourquin and Seidler, 1986; Levin, et al., 1987; Hall, 1995). These include: 1) knowledge of how to detect and enumerate the GMO; 2) estimates on organism survival, multiplication, and potential competitiveness; 3) transport and subsequent colonization; 4) possible transfer of genetic traits; 5) the ability to cause adverse environmental effects including a) disruption of environmental processes, and b) pathogenicity, toxicity, infectivity. Useful technical guidance applicable to further risk assessment issues can be found in the July 1994 and November 1994 publications of the US EPA Risk Assessment Forum and in Sayler and Sayre, 1995 . These technical issues are now characterized in further detail and are presented as a central theme for conducting risk assessments of GMOs. IIIA. The need to detect, identify, and enumerate: The most fundamental requirement for GMO risk assessments is the necessity to have an absolutely specific means to detect and enumerate the target GMO from environmental samples (Bourquin and Seidler, 1986; Levin, et al., 1987). This makes it possible to detect and document any hazard should one exist, and evaluate the components of the "exposure" side of the risk assessment equation (survival, multiplication, transport and competitiveness). The enumeration procedure must be so specific that the GMO can be readily distinguished from indigenous microbes of the 26 ------- same species. This simple requirement may be complex in practice because of the diversity of habitats that must be sampled and the lack of any single methodology applicable to recovery of GMOs from all habitats (Donegan, et al.,1991; Angle et al., 1994). IIIB. Conditions Impacting Survival, Multiplication, and Competitiveness In the environment: By having a general understanding of the ecology of the GMO and knowledge of the release habitat, certain generalities may be developed regarding expectations for the survival and potential for regrowth of the test organism. For example, if the GMO strain was isolated from the intestine of an insect, it may be expected to better colonize that habitat when reintroduced into nature than to colonize soil (Armstrong, Porteous, and Wood, 1989). Such a microorganism obtained from an insect also might be more readily transported off-site through colonization of other insects. Knowledge of the maximum growth temperature of an organism will also be useful in estimating hazards. For example, a recombinant organism isolated from soil and having a maximum growth temperature of 32C, would be most unlikely to colonize the gastrointestinal tract of a warm blooded animal, let alone cause a disease in such a host. On the other hand, Scanferlato et al. (1989) studied the survival of a genetically engineered Erwinia carotovora in aquatic microcosms. This plant pathogen did poorly and did not become established and did not survive beyond 32 days. 27 ------- Understanding the capabilities and conditions that may lead to growth in the environment might be conveniently accomplished through pilot studies in contained environments such as in microcosms or greenhouses (Fredrickson and Seidler, 1989; Cripe, Pritchard, and Stern, 1992; Hood and Seidler, 1995; Krimisky, et al., 1995). Gillett and Witt (1978) have defined a microcosm as "... a controlled, reproducible laboratory system which attempts to simulate the situation in a portion of the real world." The intent is that the microcosm duplicate as faithfully as possible, environmental conditions in order to simulate the proposed field site. Perhaps the most relevant practical use of microcosms is that they can provide results that can be used to recommend how often to sample, where to sample, and what general concentrations the GMO may be anticipated in the field environment. Furthermore, research has demonstrated that studies in these contained environments may provide a first approximation of anticipated fate/survival in the field (Bentjen at al., 1988; Armstrong, 1989; Bolton et al, 1991; Angle et al., 1995; Wagner- Dobler, et al., 1992). Other natural factors that influence survival may otherwise be difficult to anticipate and may include an ability to persist under starvation conditions; grow in association with other organisms (intestines of animals, insects, rhizosphere of plants), or with decaying tissue of plants or animals. All the latter situations also may be simulated in microcosms. A valid concept has been raised in risk assessment discussions: "what cell densities are important in assessing risks and is there a threshold response level below which any potential risks will diminish?" For 28 ------- example, in order to exhibit detectable metabolic activities, approximately 106 to 10? cells/gm or per ml will be required to induce a detectable event, whether it be production of transconjugants, change in a substrate concentration, outcompeting indigenous microflora, etc. (Short, Seidler, and Olsen, 1990; De-Leij, et al,, 1994; Doyle, et al., 1992; Olson, et al., 1990; Ripp, Ogunseitan, and Miller, 1994; Walter, et al., 1991). If the GMO has declined to less than 103 cells/gm it is very unlikely an undesirable metabolic or ecological event effect would occur, let alone be detected. It is conceivable however, that a critical environmental substrate could allow the GMO to multiply and achieve significant levels but there are few known examples where this has occurred except for disease processes in animals and plants. For documented situations where GMOs have multiplied significantly following their release into the environment the reader is referred to: Armstrong, Porteous, and Wood, 1989; Raaijmakers, et al., 1995; De Leij, et al., 1995. Whatever the GMO is designed for, it is likely that large cell densities (in excess of 107 cells/gm) will be necessary for it to carry out its intended function in the environment. Periodic sampling in microcosm habitats over several weeks to months will provide useful data for anticipating cell numbers that a specific GMO might achieve. IIIC. Fate (dispersal and transport) of GMOs: With regard to transport and fate, it has been demonstrated with early field experiments and on a smaller scale with microcosms that wind, water and insects can transport GMOs from the original site of deposition 29 ------- (Armstrong, et al., 1989; 1990; Lighthart and Kim, 1989; Seidler and Hern, 1988; Seidler, et al., 1994). These studies revealed that once a GMO is released into the environment, it can spread. This is not an unexpected observation but few earlier studies failed to investigate the transport of microbes with such specificity and detail. Transport with GMOs has been illustrated not only through a simple physical change of location in soil, but also a change in the habitat as well. Thus, it has been shown that bacteria can travel from a leaves to insects, to soil (Armstrong, et al., 1989, 1990). Therefore, when planning a field release locale investigators, regulators, and the general public should realize that dissemination may occur to a certain extent. Movement of the GMO will not necessarily be a risk per se but mobility should be taken into consideration as a component of the risk assessment relationship. Mobility could lead to GMO establishment at new sites, perhaps in new habitats, and therefore, may lead to new exposures. There is obviously a need to understand fate and rate of transport to evaluate exposures in the environment. Test procedures are available for assessing fate of GMOs in microcosms. These model ecosystems can provide very useful information that deal with GMO dispersal, transport, survival, and potential effects but obviously they are scale limited (Angle, et al., 1995). It is presumed thai there are interactions of biotic and abiotic components as well as fundamental ecological processes in microcosms that reflect processes in the environment. Studies clearly have 30 ------- demonstrated that a key to the successful application of microcosms is the necessity of controlling and monitoring environmental conditions during the course of the experimental period (Armstrong, 1989; Wagner- Dobler et al., 1992). An advantage of using microcosms is that they can be constructed to contain fewer complexities compared to the natural environment however, this simplification in itself can be a disadvantage because the natural environment is not simple. Obviously microcosms are closed systems while natural ecosystems are open. HID. Gene flow and recombination Gene transfer has been documented to occur within more than two dozen bacterial genera and numerous additional species (Levin, et al., 1992). In order for gene transfer to occur between microbes, certain physiological, metabolic and cell density requirements must be met. Gene transfer under artificial situations in the laboratory or in microcosms usually requires millions of cells per unit volume of material in order to obtain detectable transfers (Knudsen, et al., 1988; van Elsas and Smit, 1994). Because these metabolic and cell density conditions are not thought to occur with any regularity in the natural environment, some believe that gene transfer among GMOs and the indigenous bacteria is an extremely infrequent event. However, more recent data lead to other conclusions. The three well characterized mechanisms by which bacteria may undergo genetic exchange (transformation, transduction, and conjugation) are, in all likelihood, operational in soil (van Elsas and Smit, 1994; Smit, et al., 1991). Recently, studies from two laboratories have rigorously 31 ------- demonstrated that gene transfer from experimentally released bacteria into indigenous bacteria has occurred in a watershed and an aquifer (Fulthorpe and Wyndham, 1991; Zhous and Tiedje, 1995). Transduction and conjugation also have been experimentally demonstrated to take place in the phylloplane, rhizosphere, and epilithon of rocks in a stream (Farrand, 1992; Knudsen, et al., 1988; Kidambi, et a!.. 1994; Hill, et al., 1992). Soil and its component parts have been demonstrated to be both a hinderance (compartmentalization) and a stimulator (nutrients, rhizosphere effect) of gene transfers. It also has been confirmed that when the recombinant DNA is maintained in the chromosome as opposed to on a transmissible plasmid, the incidence of gene transfer by conjugation generally drops to undetectable levels as anticipated (Smit, et al., 1991; Smit, van Elsas, and van Need, 1992). Thus, if one is prudent in the molecular design of the recombinant organism and can avoid habitats that promote cell contact, high cell densities, and is low in available substrates for growth, the transfer of recombinant DNA into indigenous bacteria is surely not a detectable event. Recently, evidence also has accumulated that bacteriophage mediated transduction plays a significant role in the transfer of both plasmid and chromosomal DNA in aquatic ecosystems (Ripp and Miller, 1995). Using lake water microcosms incubated in a freshwater lake, investigators demonstrated that t particulate matter increased transduction up to 100- fold. Furthermore, up to 40% of the Pseudomonas aeruginosa in natural systems contain DNA sequences homologous to phage genomes indicating 32 ------- probable prior interaction with a transducing bacteriophage (Ogunseitan, et al., 1992) . It is well documented that gene transfer between bacteria requires specific physiological, nutritional, and environmental conditions. These conditions can be met in a variety of habitats where natural cell densities are sufficient to promote necessary cell, bacteriophage, or naked DNA interactions to allow genetic exchange to occur at detectable rates. DNA transfers of recombinant genes have been facilitated by naturally occurring mobilizing plasmids in river epilithon where bacterial numbers are very high on rock surfaces (Hill, Weightman, and Fry, 1992). IIIE. Characterizing Ecological Effects. The experimental search for ecological effects from GMOs has taken a tortuous and intellectually challenging route because of the potential political, social, economic, and scientific consequences and challenges of finding such an organism. Uncertainties over possible ecological effects probably are derived from a combination of our uncertain and limited knowledge of microbial ecology and the documented "horror" stories of significant and adverse effects from introduct'ons of certain higher species of plants and animals (Sharpies, 1990; Halvorson et al, 1985). Scientists have tended to speculate that certain undesirable consequences brought about by higher plant and animal introductions might be extended to GMOs. This has perhaps sensationalized the anticipated discovery of GMO-induced effects and made the documented effects seem less 33 ------- important. Sharpies (1990) has compiled a list of characteristics that probably assist in the establishment of new organisms in new niches. An inspection of these traits reveals their applicability to microorganisms as well as to higher organisms: "the organisms with generalized requirements and broad tolerances seem to make better invaders exploiting a used or underused resource will facilitate establishment unique physiological features, as in the ability to metabolize unusual compounds may facilitate establishment an organism may survive better if it is preadapted to survive when the new habitat is like the one in which it evolved." It may prove valuable to keep these concepts in mind as new GMOs are constructed and examined for possible environmental perturbations. Despite the verifications that GMOs may undesirable changes in a habitat (Short, et al, 1991; Doyle, et al, 1991; Seidler, 1992; Doyle, et al., 1995), questions remain as to how best to evaluate and detect these potential detrimental effects with new GMOs. Another equally perplexing issue is a criticism as to 'the, significance of an effect that is "transient" in nature as opposed to one that is longer in duration. First, of course one must be entirely certain that the recovery from a "transient" effect actually 34 ------- leaves the habitat in a "recovered" state that is unaltered from its original structure and function. Most investigations have used only broad,- general assays to monitor habitat changes induced by GMOs. However, when detailed methodologies are used to track perturbations, evidence for taxonomic changes in bacterial populations has been revealed, despite the return in culturable bacterial numbers to control levels (Donegan, et al, 1995). Many endpoints have been considered in evaluating possible effects from GMOs (Table 1). Initially, it was not obvious which endpoints would be the most logical to investigate. A "shotgun approach" was used in early research with hopes of capturing GMO-induced alterations (Seidler, 1992; Doyle, et al., 1995) . This approach resulted in the detection of effects documented in changes of respiration, cell numbers, and certain soil enzymes (Doyle et al., 1991; Short et al, 1991; Wang, et al., 1991). Monitoring these population changes and other risk assessment experiments can be conducted readily and, perhaps should be conducted, in microcosms. Population trends, biochemical activities, mineralization or leaching of soil enzymes and plant biomass trends also have been investigated and documented to be useful when monitoring for GMO perturbations (Bolten, et al., 1991). The day may be approaching rapidly when experimental trials of GMOs will be-routinely conducted in the open environment with little to no preliminary microcosm investigations. This certainly has become the trend in testing transgenic plants (Mellon and Rissler, 1993). Another 35 ------- approach to initial or preliminary assessments of GMOs may be to conduct field trials with the unaltered parental strain. In this case there may be doubt if the parental strain would accurately mimic key ecological traits that pertain to risk assessment aspects of the GMO. Chances are that differences in key metabolic characteristics of the GMO may significantly alter its survival and this may influence its characteristics for exposure or hazard assessments. Therefore, if experiments are to be conducted in microcosms, this should be done using the (recombinant) GMO strain. IMF. Health Effects The deliberate environmental release of GMOs has initiated investigations of potential health effects associated with exposure to these organisms. Humans may come into contact with these microorganisms or their products in the agricultural or industrial setting during production or application (Grunnet and Hansen, 1978; Olenchock, 1988). Because soil, water, or air may contain high concentrations of the microbial product, the primary routes of exposure are through inhalation, ingestion, or skin penetration (Levy, 1986). The new Escherichia coli host-vector systems constructed during the initial recombinant DNA studies in the 1970s raised several human health issues (Gorbach, 1978a; Gorbach 1978b). Colonization of the intestinal tract and transfer fo and expression of foreign genes by the intestinal microbiota was of particular concern. Researchers studied the colonization of the human Gl tract by E. coli strains K12 and B (and their 36 ------- derivatives) and found that the colonization of normal healthy adults did not occur (Anderson, 1975; Levy et al, 1980; Smith, 1975; Smith, 1978), However, E. coli strains were able to establish in the intestines of germ- free and antibiotic-treated mice (Cohen et al, 1979; Laux et al., 1981; Levy and Marshall, 1981; Levy et al., 1980). Gene transfer to the normal human intestinal flora was plausible, but E. coli strains harboring plasmids were demonstrated to have a selective disadvantage in their colonizing ability (Anderson, 1978; Duval-lflah and Chappuis, 1984; Laux et al., 1982). Aside from the pesticide products that require health effects testing as described in Subdivision M of FIFRA, little health effects research has been done on biotechnology agents and their products or by-products. To date, the general consensus has been that because the strains used for biotechnology applications are of little risk to "normal" people, more research emphasis has been placed on environmental effects. However, as research into potential health effects is conducted, the health effects of some biotechnology strains may be less certain than previously thought. As summarized in Table 2, the majority of the published research has dealt with microorganisms used for biodegradation or the by-products of this process. Recently, Health Canada has completed an extensive study on the pathogenicity of environmental and clinical P. aeruginosa (because of its potential application for biodegradation) isolates looking at a variety of endpoints which will be addressed in Section IIF(1) (Godfrey et al., 1996). 37 ------- In general, there are two fundamental questions that should be answered when considering health effects associated with biotechnology agents and products: 1) Does the microorganism(s) involved impact health, and 2) does the microbial product or by-product result in an increased health risk? In order to address these questions, 3 general areas will be explored and their relevance discussed. Included are 1) pathogenicity (comprised of mortality, morbidity, and infectivity), 2) allergenicity of both the product of interest and the microbial component, and 3) product (or by-product) toxicity. (1) Pathogenicity The likelihood of an industrial release of a known pathogen is very low. In fact, the Federal Register statutes (1986) regulating the release of GMOs mandate that the organism used not be pathogenic. However, because of the increased exposure potential and the possibility for the use of identified or unknown opportunistic pathogenic agents, it is imperative to determine if an organism has the probability to infect workers or the general public. Therefore, several in vivo and in vitro systems have been used to determine if biotechnology agents and their products are potentially hazardous. Many of these use rodent models to determine morbidity and establish LD5o values. For example, Roe et al., (1991) have demonstrated that the solubilized parasporal crystalline protein of Bacillus thuringientis subsp. israelensis has an LD50 of 1.3 mg/kg following i.p. injection of the Swiss-Webster mouse . The LD50 in the CD rat is 9 mg/kg. Following intranasal exposure, George et al. (1993) have 38 ------- established an LD5o of 1.05 x 107 CFU for P. aeruginosa strain AC869 in the C3H/HeJ mouse. In order to cause disease, an organism must evade or overwhelm the defense barriers of its potential host and multiply. Therefore, survival temperature range plays an important role in the infection process. As stated earlier, if an organism cannot survive above 30°C, it is unlikely that it will persist and multiply in a mammalian host. However, if the microorganism can persist at the host temperature, it can attach to or invade host cells. A list of temperature ranges for selected biotechnology agents are presented in Table 3. Additionally, in order to achieve colonization, an organism must avoid the host immune systems. Once inside the cell, an organism may multiply and be disseminated throughout the host. Pathogenicity factors, such as adhesins, extracellular enzymes, and cytotoxins, may enhance disease progression. However, disease is an inadvertent outcome of infection (Finlay and Falkow, 1989). Production of pathogenicity factors by an invasive microorganism may facilitate infection (Finlay and Falkow, 1989). Significant attention has been given to pathogenicity factors attributed to P. aeruginosa and other pseuriomonads (Table 4). Members of the genus Pseudomonas are used for environmental applications because of their effectiveness in biocontrol and versatile substrate utilization abilities. Even though most of these microorganisms generally are considered harmless soil isolates, they may cause opportunistic infections following exposure of susceptible individuals to high concentrations. P. aeruginosa is recognized as an 39 ------- opportunistic human pathogen and is capable of causing disease, especially in immunosuppressed hosts and patients with leukemia or cystic fibrosis (Bodey et al., 1978; Schimpff,1980; Guiot et al., 1981). Grimwood et al. (1993) have concluded that exoenzyme expression correlates with lung deterioration in cystic fibrosis disease progression. Some isolates of Burkholderia cepacia (formally Pseudomonas cepacia) are involved in nosocomial infections (Martone et al., 1981) and can colonize and cause pneumonia and septicemia in cystic fibrosis patients (Rosenstein and Hall, 1980; Sajjan et al., 1992). P. putida, P. fluorescens, and Xanthomonas maltophilia (formally Pseudomonas maltophilia) have been shown to cause secondary infections in cancer patients and are involved in other opportunistic infections (Gilardi, 1991; Anaissie et al., 1986). In order to establish regulations for biotechnology products, Health Canada has investigated several endpoints for use in the risk analysis of P. aeruginosa, a potential isolate of bioremediation products (Godfrey et al., 1996). Clinical and environmental isolates have been screened for exoenzyme production (Toxin A, protease, phospholipase C, exoenzyme S, elastase), cytotoxicity, serotype, serum sensitivity, phagocytic killing, opsonic phagocytosis, A and B band LPS probe reactivity, pilus phage sensitivity, and restriction fragment length polymorphism type. Of all of the endpoints measured, exoenzyme S is the only one to demonstrate a good correlation to, mouse virulence (LD50 in the neutropenic mouse model) with elastase production showing possible correlation to LD50. Because the mechanism of pathogenicity by P. aeruginosa is multifactorial, the 40 ------- elimination of one pathogenicity factor, such as exoenzyme S, may not eliminate pathogenicity (Godfrey et al., 1996). Others have suggested that, with the exception of alginase production by P. aeruginosa cystic fibrosis isolates, that there is no one factor that differentiates between clinical and environmental isolates of P. aeruginosa and B. cepacia (Nicas and Iglewski, 1986). However, Bevivino et al. (1994) have shown that rhizosphere isolates do have several unique traits, not found in their clinical counterparts, such as wider temperature range for growth, nitrogen fixation ability, and indole acetic acid production. In this study, clinical isolates produced protease and pyochelin, and adhered to human cells. (2) ailergenicity A second category of deleterious outcomes following human exposure to biotechnology agents and their products is an allergic reaction. This can culminate in a skin reaction or a more serious respiratory response to the allergen such as bronchitis and/or asthma. Because a variety of fungi can cause severe respiratory reactions, it is especially important to consider the potential ailergenicity of fungal pest control agents such as Metarhizium anisophilae and Beauvaria bassiana. Additionally, bacterial strains that secrete extracellular enzymes and/or polysaccharides may be allergens. An extensively studied enzyme product that elicits an allergic reaction is alcalase (subtilisn). Following its introduction into the detergent industry in the late 1960s, this alkaline protease, produced by Bacillus 41 ------- subtilis and supplied by Novo Industri A/S (Bagsvaerd, Denmark), was identified as a Type I (IgE) respiratory allergen (Flindt et al., 1969; Pepys et al., 1969). Franz et al (1971) reported respiratory symptoms in detergent industry workers 3 to 8 hours following their work shift. Another group at risk, the consumer, also has been shown to develop respiratory symptoms from exposure to the enzyme component in the detergent (Shapiro and Eisenberg, 1971). Detergent industry workers were closely monitored once alcalase was identified as the allergen. Several studies of workers have been reported that correlate exposure to a positive skin prick test and total serum IgE levels (How et al., 1978; Shapiro and Eisenberg, 1971; Weill et al., 1971). Once exposure control was implemented in the detergent plant (e.g. dust levels reduced, protective clothing worn by enzyme handlers), fewer instances of respiratory allergenicity were reported. Additionally, because acceptable exposure levels have been established for Alcalase, it now is used as the benchmark for comparison of new enzyme products (Sarlo et al., 1991). A third area of potential allergen exposure arises from the consumption of transgenic plants. The Food and Drug Administration has conceded that it is possible for genetically modified plants to express foreign proteins that could cause the food to be allergenic and now has a protocol to help regulate potentially allergenic transgenic foods (Nestle, 1996). Interestingly, Nordlee et al. (1996) identified a Brazil nut allergin in an engineered soybean, which expressed brazil nut albumin. Therefore, it is 42 ------- important to determine if an engineered food has an allergenic potential so that the consumer can be notified of potential risks. (3) By-product toxicity Use of bioremediation to reduce or eliminate hazardous waste is economically important. The ultimate goal of waste management is to eliminate toxicity of the waste and reduce risk of exposure to the remaining hazardous components. There are many bacteria and fungi that can metabolize, or co-metabolize, many complex chemicals either alone or in consortia, both aerobically and anaerobically. However, the scenario at the hazardous waste site or biodegradation facility may not be as controlled as the laboratory incubator, so a biodegradation process may not occur as readily or identically as that observed in the laboratory. Therefore, because the reduction of one compound does not necessarily indicate reduced toxicity of the resulting by-products, a variety of methods can be used to determine if a chemical degradation process reduces the overall toxicity (cytotoxicity, genotoxicity, teratogenicity, neurotoxicity) of the target compound(s) or complex mixtures. There are two general approaches to toxicity reduction: 1) if one or a few chemicals are involved and if the metabolic pathway(s) is known, then the toxicity of the metabolites can be established and the toxicity of the process predicted, 'and 2) if the metabolic pathway is unknown or if the target is a complex mixture of chemicals, then extracts from benchscale biodegradation processes can be analyzed for a reduction in overall 43 ------- toxicity prior to large scale use. An example of the first scenario is that of pentachlorophenol (PCP) degradation. The pathway for PCP degradation from anaerobic sewage sludge studies is shown in Figure 1 (Mikesell and Boyd, 1988). PCP induces hepatic carcinomas and adenomas in mice and chromosomal aberrations in Chinese hamster ovary cells (DeMarini et al., 1990; NTP, 1989). The metabolites 2,3,4,5-tetrachlorophenol and 3,4,5- trichlorophenol are more genotoxic than the parental compound PCP in the prophage induction bioassay in E coli (DeMarini et al., 1990). Tetrachlorohydroquinone, a major PCP metabolite identified in rodent studies, is genotoxic in V79 Chinese hamster cells and may be responsible for oxidative DNA damage in vivo (Jansson and Jansson, 1991). A similar scenario occurs following 2,4,5-trichlorophenoxyacetic acid (2,4,5-T) metabolism by B. cepacia (George et al., 1992). One of the metabolites, 2,4,5-trichlorophenol is 100-fold more genotoxic than the parental compound in the prophage induction bioassay. Therefore, if the parental compounds PCP and 2,4,5-T are metabolized, the chlorinated intermediates of these compounds may accumulate, and the resulting toxicity may be considerably higher than that observed for the unremediated waste. Because the metabolic pathway is known for PCP and 2,4,5-T, and the resulting intermediates are more toxic than the parental compounds, strains can be constructed that do not accumulate the more toxic intermediates or other microorganism with alternative degradative pathways can be employed for the bioremediation process. Toxicity tests have been used to monitor the toxicity of hazardous waste sites and bioremediation (Table 5). Claxton et al. (1991a; 1991b) used the 44 ------- Salmonella assay to assess the genotoxicity during the bioremediation efforts following the Alaskan oil spill (March 1989) in Prince William Sound, Alaska. The efficacy of two fertilizers, one oil soluble and the other water soluble, was studied. The reduction or generation of toxicants during bioremediation was of particular interest. The results concluded that the mutagenicity declined over time and that both the naturally occurring processes and fertilizer supplement contributed to the reduction in toxicity. IV. Examples and Methods for Detecting Effects Caused by GMOs 1VA. Environmental Perturbations from GMOs What kinds of environmental perturbations might be anticipated in a worst case scenario involving a GMO? Are there any precedents in the literature that might provide answers to this question? There are now many examples of documented effects on beneficial organisms or ecosystem processes induced following exposure to a GMO (Table 6). Overall, the documented effects include the transfer of genetic material to indigenous bacteria, production of toxic metabolites, changes in metabolic activity of the soil community, competition resulting in the suppression of indigenous microorganisms, and changes in the biodiversity of organisms present in the habitat. These changes represent exactly the kinds of perturbations that were speculated as possible occurrences early in the risk assessment of GMOs (Halvorson, et al.,1985; Bourquin and Seidler, 45 ------- 1986). GMOs that are effectors of ecosystem perturbations also represent a large and diverse type of taxonomic and metabolic groups. Perhaps more studies have been conducted with a plant/soil ecosystem to explore possible GMO effects than with any other system. The first field studies in the United States involved the release of Ice- Pseudomonas syringae onto strawberries and potatoes to control frost damage (Seidler and Hern, 1988;Seidler, et al., 1994). In those experiments it was learned that despite reasonable precautions, the aerosol spray of the GMO resulted in considerable drift off the main plot. Although elaborate monitoring devices were employed, it was soon learned that large (150 mm dia) Petri dishes could adequately serve as indicators of the extent of microbial deposition on and off the plot. Only 0.001% of the sprayed P. syringae drifted some 30 m off the central plot area. This still translated into a considerable number of viable cells (est 107). Although this increased transport occurred, no known undesirable consequences resulted. This may not always be the case with other GMOs. Therefore, it is prudent to anticipate dispersal of a GMO beyond the boundaries of a test, especially in aerosol releases. Monitoring may easily be conducted as described above to document drift for cases where legal or sensitive environmental issues may be involved. Two studies assessing similar potential GMO effects were carried out independently in different parts of the world and the results merit special mention. The studies conducted by Fredrickson et al, (1989) and by White, et al., (1994) both evaluated the possible impacts caused by a different 46 ------- root colonizing GMO on the bacterial flora associated with wheat. In both cases a Pseudomonas species was the GMO and in both cases the introduced organism resulted in substantial reductions in indigenous microbial populations found naturally on wheat seeds and root systems. At least in one case the introduced organisms suppressed other fluorescent pseudomonads, organisms that help to reduce the incidence of take-all disease, a fungal disease of wheat. In other studies, it was learned that GMOs placed on seeds or inoculated directly into soil were capable of moving or being transported to the aerial parts of plants. For example, insects could vector GMOs between soil and plant parts and even on to new insects via contaminated leaves (Armstrong, et al.,1989, 1990). In a recent study, plant growth promoting fluorescent pseudomonads colonized the surface and interior tissues of cotyledons in row crops following initial inoculation onto seeds (Raaijmakers, et al., 1995). It is clear that at least with some applications of GMOs, transport may be the rule rather than the exception to their ecological fate. Two documented cases have been described of GMO effects resulting from the production of metabolites. These studies validate the potential concern that an introduced taxon can significantly alter its surroundings. Streptomyces lividans has been genetically modified to enhance its production of extracellular lignin peroxidase and hydrogen peroxide to facilitate the degradation of lignin (Wang, et al.,1989). Whenever the recombinant strain was added to native soil supplemented with lignin, 47 ------- there was an increase in the amount of carbon dioxide respired over all control treatments. Because GMO strains did not cause an increased evolution in carbon dioxide in sterile soil, the researchers hypothesized that the enzyme-induced lignin breakdown by the GMO provided fresh substrate for indigenous soil microflora and this synergistic relationship caused the enhanced mineralization of carbon. Thus, the lignin peroxidase produced by the GMO had a significant short term impact on carbon turnover rates that peaked out by day 6-9, presumably when the added lignin had been biodegraded. The synergism established between an added bacterium (GMO) and components of the indigenous microbiota illustrate dramatically how a GMO may interact with and influence the metabolic characteristics the indigenous community. It would be of great interest to determine whether the breakdown of natural or added lignin had any impact on other soil parameters such as fertility, moisture holding capacity, pH, etc, and what proportion of the resident lignin can be decomposed by this GMO. In this case, microcosm studies could provide answers to both sets of questions. The second case of a deleterious GMO metabolite resultad from an unanticipated combination of ecological and biochemical circumstances. The use of GMOs as agents of bioremediation to facilitate environmental cleanup is a most'worthy goal. However, the metabolic limitations and capabilities of any altered metabolic traits should be well documented prior to open field trials to evaluate efficacy. A case in point that 48 ------- illustrates this caution is the P. putida PPO301 (pRO103) organism that is capable of degrading 2,4-dichlorophenoxyaeetic acid (2,4-D). When this GMO was added to a soil microcosm containing added 2,4-D, the first metabolic product of 2,4-D breakdown, 2,4-dichlorophenol(2,4-DCP), accumulated to 70-90 ug/g of soil. The 2,4-DCP is more toxic than 2,4-D and fungal propagules in the experimental treatment deceased from over 3 x 106 to undetectable levels by day 18 (Short, et al., 1991). Toxicity of the 2,4-DCP also was demonstrated on Petri dish assays where relative fungal counts were determined in the presence of increasing concentrations of 2,4-DCP. Growth of all soil fungi was reduced by as little as 10ug/ml of media of 2,4-DCP and by 25 ug/g of soil in other pure culture assays. Interestingly, the 2,4-DCP did not reduce the numbers of soil bacteria. The accumulation of 2,4-DCP was the result of two factors. First, the bacterium could not degrade 2,4-D completely so the 2,4-DCP accumulated. Furthermore, the arid soil used in these studies did not contain any indigenous microbes capable of degrading 2,4-D or 2,4- DCP. Thus, in this soil with this GMO, 2,4-DCP accumulated. These observations are also valuable because they validate the use of microcosms for investigating ecological perturbations and the results were easy to measure since changes in microbial populations were the impacted endpoint. IVB. Toxicological considerations f In this section, in vivo models and tier testing approaches will be presented for use In determining the potential pathogenicity, infectivity, 49 ------- and allergenicity of- biotechnology agents and their products. In a previous section [IIF (1)], endpoints that are characteristic for pathogenic strains were described so pathogenicity and infectivity factors will not be discussed further in this section. (1) in vivo infectivity and pathogenicity models. Several animal models have been used to detect potential health effects of biotechnology agents and their products including conventional mice (with and without fasting) and rats (Table 7). From these animal models, LD5o values can be established. Aside from mortality, morbidity endpoints including body and tissue weight loss, heart rate, hypothermia, vasodilation, jejunal hemorrhaging, liver centrilobular congestion have been detected (Roe et al., 1991; George et al., 1991; George et at., 1993). Additionally, clearance (from the lungs, small and large intestine, cecum), colonization (Gl tract), translocation (spleen, liver, mesenteric lymph nodes), and pulmonary inflammatory response have been determined following oral or intranasal exposure (George et al., 1989, 1991, 1993). Other animal models that may be useful for determining the mortality and morbidity of GMOs are: 1) pulmonary exposure of rats to agar or pgarose encapsulated P. aeruginosa or other organisms (Cash et al., 1979; Starke et al., 1987; Woods et al., 1980), 2) neutropenic mouse model to determine LD5o (Godfrey et af., 1995), and 3) the Streptococcus zooepidemicusfinfluenza virus pulmonary exposure mouse model (Sherwood et al., 1988). The latter has been used to determine health 50 ------- effects of P. aeruginosa, B. cepacia, X. maltophilia, and B. thuringiensis subsp. israelensis, B. thuringiensis subsp. kurstaki, and B. thuringiensis subsp. aizawai (George et al., 1991; George et al., 1993; Kawanishi et al., 1990). (2) Allergenicity. Sarlo and Clark (1992) have described a tier approach to determine the respiratory allergenicity potential of low molecular weight chemicals. This strategy has application for biotechnology chemical products and may be suitable for protein products. The tier approach is shown in Figure 2. If a chemical can modify a protein, then there is a potential to yield an immunogenic chemical-carrier conjugate (Sarlo and Clark, 1992). The ability of a biotechnology product to react with a protein demonstrates its potential as an allergen. The Level 3 guinea pig injection model involves subcutaneous injection of the potential allergen in an olive oil carrier over a period of 6 weeks. At the end of the treatment regiment, respiratory reactivity (following intratracheal challenge of the potential allergen), active cutaneous anaphylaxis testing (intradermal injection with the chemical protein conjugate using Evans blue dye intracardially injected as the indicator), and allergen-specific IgE levels are measured (EUSA). Guinea pig inhalation tests constitute the final tier (level 4). Animals are servsitized by exposure to aerosols for 5 days (3 h/day) and respiratory rate and breath peak height continuously monitored. Two weeks following 51 ------- sensitization, animals are exposed to an aerosol and respiratory rate and breath peak height determined over a 30 min period. Readers should refer to the Sarlo and Clark (1992) reference for a more detailed description of the Levels 1-4 procedures. Skin testing of detergent factory workers has been used to identify atopic individuals (How et al., 1978; Newhouse et al., 1970; Franz et al., 1971; Juniper et al., 1977). Subjects were injected cutaneously with different concentrations of alcalase protein in physiological saline and the skin response observed (Sarlo et al., 1990; How et al., 1978). (3) Tier testing approach for microbial and biochemical pest control agents. The United States Environmental Protection Agency regulates new microbial and biochemical pest control products using the approach presented in Subdivision M of the Pesticide Testing Guidelines (Anderson et al., 1989). The Tier I toxicology guidelines, which address acute oral, dermal, pulmonary, and intravenous toxicity and pathogenicity as well as eye irritation and infection, hypersensitivity, cell culture tests (viral agents) are suitable for GMOs. Tier II testing describes methods for acute and subchronic toxicity/pathogenicity studies, and Tier III focuses on 1) reproductive and fertility effects, 2) oncogenicity studies, 3) I immunodeficiency studies, and 4) a primate infectivity and pathogenicity study. Even though the guidelines are established for regulation of pest control agents, they have some applicability for determining health 52 ------- effects of GMOs. IVC. Reliability of endpoint measurements In order to assure workers and the population at large, the safety of environmentally released GMOs must be established. If a potential environmental release is not from a pathogenic genus, health or environmental effects testing on this particular microbial strain may not have been done. Even though the probability is low, there is a potential for GMOs to harbor genes harmful to human health or the environment. By developing, validating, and using methods that examine the potential effects of the newly generated strains, such as those described in the previous sections, researchers and industry can reassure the workers and the general public that the isolates are safer. In order to reliably evaluate measurements conducted on environmental aspects of GMO risk assessments, properly designed ecologically relevant experiments are essential. It is crucial that any prerelease studies be conducted with environmental materials that will ultimately receive the GMO. Thus, local water, soil, plants, etc should be employed. This commonsense approach to evaluating survival, transport, and effects will help to ensure that relevant and hopefully reliable information on the ecology of the organism will be obtained. As indicated in Table 1, r numerous experimental endpoints have been tested or proposed to measure risks associated with GMOs. A recent publication discusses many of these endpoints (Stotzky, et a!., 1993) and the reader is referred to that report 53 ------- for a more detailed analysis. One of the keys to taking reliable endpoint measurements is the ability to control the environment in which microcosm analyses may be evaluated. Without proper environmental controls to measure and control light, temperature, soil moisture etc., there is little hope of either simulating natural conditions or to obtaining repeatable data on basic ecological parameters such as GMO survival. How and when to sample the environment to measure endpoints can best be obtained from published data on other GMOs and from trial and error experiences. Basic microbiological techniques that ensure sample integrity is maintained free from extraneous contaminants, a reliable procedure to detect and enumerate the exact strain under test, and a reasonable culturing milieu are all necessities. As stated earlier, we also have found when conducting field trials that a quality assurance plan must be in place to insure the quality and repeatability of the data collected (Seidler and Hern, 1988). The determination of potential health effects of GMOs is not a precise science. The selection of an animal model to determine morbidity and mortality of all relevant GMOs is difficult. It is important to consider clearance rate of the GMO from the animal tissues because human pathogens do not necessarily cause disease in animal models. Exoenzyme and toxin production, in combination with the toxicology data, are helpful f in determining if there is a potential for adverse health effects. However, the pathogenicity factors described previously are from the Pseudomonas species because of the widespread use of the pseudomonads in 54 ------- bioremediation and other environmental applications (predominantly P. aeruginosa has been studied). Additionally, Godfrey et al. (1995) have shown that only the pathogenicity factor exoenzyme S correlates with LD50 in P. aeruginosa isolates tested even though Grimwood et al. (1993) have demonstrated a correlation between several exoenzymes and cystic fibrosis lung deterioration. Therefore, the possession of pathogenicity factors by a biotechnology agent may impact the potential risk associated with exposure. However, if the GMO of interest does cause mortality, morbidity, or it colonizes a selected animal and if it has some of the recognized pathogenicity factors (a pest control agent for example), then the potential to cause adverse human health effects may increase. This information, along with the exposure data, should be considered prior to release of the GMO. Generally speaking, healthy adults should not experience any adverse reactions following exposure to GMOs. However, because some of the GMOs proposed for environmental release may cause opportunistic infections, there are several groups of individuals that may be at a greater risk following exposure due to their immune status. These groups include 1) young children and infants, 2) the elderly, 3) chemotherapy patients, 4) individuals with an active illness, 5) convalescents using antibiotics or other'medications, and "6) atopic persons . For example, isolates of B. cepacia, an organism found in the soil, cause disease in cystic fibrosis victims (Rosenstein and Hall, 1980). Clostridium difficile 55 ------- can colonize the healthy, human adult intestinal tract in low numbers but causes pseudomembranous colitis in patients on antibiotic therapy (Bartlett, 1979). Green et ai. (1990) have examined the public health implications of a B. thuringiensis var. kurstaki spray in Oregon and have found that B. thuringiensis var. kurstaki is culturable from clinical specimens from exposed individuals. Three patients with prior medical problems harbored B. thuringiensis var. kurstaki which could not be ruled out as a causative disease agent. However, detrimental effects from controlled human exposure (oral and inhalation) to B. thuringiensis have produced no adverse effects (Fisher and Rosner, 1959). It is important to identify potential allergens so that atopic individuals can be identified and their exposure reduced. The detergent industry- alcalase experience is a case in point (Franz et al., 1971). Once researchers recognized alcalase as an allergen and identified atopic individuals, industrial exposures were reduced in the following ways: 1) workers who handled the raw materials were outfitted with protective clothing, 2) dust levels were reduced in the plants so that employees' exposures were lessened, and 3) atopic individuals were placed in jobs where exposure was reduced or eliminated. The industry continues to closely monitor its workers even though the allergenicity-related complaints have declined. Otherwise healthy individuals may have some risk following exposure to GMOs or their products. One point to consider is the transfer of antibiotic resistance genes from the environmentally released GMOs to other 56 ------- microorganisms and mammals, including humans. The spread of the antibiotic resistance genes has the potential to reduce the effectiveness of the presently-used antibiotics to fight disease. One case in point is multidrug-resistant Mycobacterium tuberculosis (Pearson et al., 1992). Because the organism is resistant to a host of currently used antibiotics, it is more difficult to eradicate the disease. Several groups have demonstrated the flow of antibiotic resistance genes from microorganisms to humans. Marshall et al. (1990) described the spread of an E. coli strain that harbored antibiotic resistance markers on a plasmid from the microflora of animals to humans. A study by Linton (1986) reported a similar finding suggesting that E. coli resistance traits can transfer from animal microflora to human microflora, ultimately rendering potential pathogens resistant to drugs and therefore much more difficult to treat. The probability of other (non-antibiotic) introduced genes to transfer from the GMOs to humans may result in some unexpected transfer of the engineered traits to humans. The long term effects of this transfer are unknown; however, there is the potential for expression of these traits. Finally, the toxicity of both the by-products and end products should be considered. This is especially important in terms of bioremediation where hazardous waste reduction and elimination may result in production and accumulation. Therefore, it is important to have an understanding of the. remediation pnocess and the ultimate biological activity (toxicity) of the finished product, not just the chemical analysis that measures elimination of the parental compound(s). 57 ------- V. Future risk assessment concerns and research needs The use of microorganisms and management of microbial activities long predates the use of pure cultures as inocula. However, it has not been until the last 10-20 years, with the advent and growth of recombinant techniques that allow the development of novel genotypes and activities, that public concerns have been raised about the safety of using microbes, particularly for intentional environmental releases. To date, three of the four engineered microbes approved for commercial use in the United States, under the Federal Fungicide, Insecticide and Rodenticide Act, are non-viable formulations of engineered microbes (P. fluorescens containing toxin genes from various Bacillus thuringiensis subspecies). Engineered microbes approved for small scale experimental environmental release under the Toxic Substances Control Act (TSCA), include P. fluorescens (P. aureofaciens) containing the lac zy gene from £ coll, P. fluorescens strain HK44 for PAH degradation, and R. meliloti containing antibiotic resistance and nitrogen fixation (nif) genes. A request for commercial registration approval under TSCA, of a R. meliloti strain containing an enhanced nitrogen fixation (nif) capability, is currently under review by the United States Environmental Protection Agency. To date, with the exception of widely used agronomic inocula such as nitrogen fixing bacteria (Rhizobium spp.and Bradyrhizobium spp.), silage inocula such as Lactobacillus spp end the microbial insecticide B. t kurstaki, relatively few inocula have been intentionally released to the environment on a large scale basis. Most of the non-agronomic applications noted above have 58 ------- either been experimental ones, performed under semi-contained conditions of laboratory microcosms or greenhouses, or they are being used under the contained conditions of fermentation tanks or other types of bioreactors. Where field data are available, numerous examples have been reported for presumably transient effects of both biologicals and chemicals, on populations and activities of soil biota, nutrient cycling and diversity (Watrud & Seidler 1996). As the size of field tests and commercial uses increase, questions about the effects of multiple applications and long term use of biotechnology products also arise. These include questions of both fate of the biologicals (organisms, nucleic acids, proteins), and ecological effects on non-target organisms and communities, nutrient cycling processes and on below ground and above ground biological diversity. However, in the absence of long term monitoring studies, and lack of consensus on suitable biological indicators or methodology, long term impacts remain unknown. Scientific issues which repeatedly have been raised regarding the release of recombinant microbes include their fate and their potential adverse effects on non-target species. In traditional chemical risk or ecotoxicological assessments, single species have typically been tested for short periods of time, under laboratory conditions. Pending results with the first "tier" of indicator organisms, additional organisms may be tested or longer term tests may be carried out. With the current increased interest 1n the use of biologicals, traditional ways of measuring persistence, transport and effects (for chemicals), need to be re- evaluated for their suitability in assessing the effects and risks of 59 ------- biologicals. Unlike chemicals, biologicals can reproduce; nucleic acids, enzymes or toxins associated with biological agents may retain biological activity in natural environments for extended periods of time. Genetic exchange between introduced and indigenous flora can result in transport and persistence of the biological activity beyond the site and time of introduction. Experience and data from large-scale, repeated or long term uses of engineered microbes, is limited. A need for research therefore continues, to answer questions regarding fate and effects of the introduced microbes and microbial products, not only at the points of release, but also in areas adjacent, downwind or downstream from the points of application or release. Methods need to be developed not only to look at single species or single site effects, but to examine effects on communities of organisms in different ecosystems in diverse geographic areas. For example, if a product is designed for agronomic use, such as crop protection, non-target effects perhaps should be examined not only within the agronomic system or on the target pest, but also on adjacent agronomic, native, weedy and horticultural species in the surrounding area. Studies on the effects of engineered microbes on soil foodweb components (plant symbionts, nematodes, litter arthropods, protozoans and microbes), on nutrient cycling, plant biomass and nutrient status and on plant community diversity, may be useful to identify early indicators of adverse effects to the diversity, functioning and sustainability of ecosystems. To facilitate the capability to handle large sample numbers, automated methods? of sample preparation, and analysis may be needed. Given a suitable data base, development of predictive models to permit estimation of risks from novel biologicals may also be useful. A need for 60 ------- longer term monitoring of effects on local and geographic bases should be considered, since as we have learned from persistent chemicals such as dichloro diphenyl tricholoroethane (DDT) and the para chloro biphenyls (PCBs), ecological effects may not be apparent until decades after their initial introduction. In summary, we have presented an overview of the complex interactions of genetically engineered microorganisms with the human and natural environments. It has become clear from this information that risk assessments of these interactions is complex and at present at a very preliminary stage of development. Additional model systems are needed involving both humans and the natural environment in order to provide reassurances that properly focused risk assessments can indeed provide reliable predictions about the potential risks of these novel life forms. Currently available data from short term experiments point towards minimal risks associated with GMOs. 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Impact of GMO on numbers or kinds of viable bacteria metabolic activity (respiration, kinetics of CO2 evolution, substrate induced respiration) numbers of Gram-negative bacteria present bacterial populations in the rhizosphere and rhizoplane species diverstiy biomass of colonized plants microbial biomass biomass of plant shoots nitrogen content of wheat shoots total viable fungi numbers of cellulose utilizers number of chitin utilizers numbers of denitrifiers numbers of nitrifiers numbers of protozoa nutritional groups of bacteria present activity of soil enzymes kinetics of nitrogen transformations numbers of nonsymbiotic dinitrogen fixers competitive ability of GMOs effects of MPCAs on mycorrhizal colonization of roots effects of MPCAs on mycorrhizal colonization and plant growth numbers of soil nematodes, mites, Collembola trophic groups of nematodes transfer of recombinant DNA to indigenous microorganisms 106 ------- Table 2. Examples of biotechnology agents and their products where health effects studies have been reported in the scientific literature. Application Microbial Strain or Product Pest Control Bacillus thuringiensis subs p. israelensis Bacillus thuringiensis subsp. kurstaki Pseudomonas syringae Autograph a californica Biodegradation Pseudomonas sp. P. aeruginosa P. putida Burkholderia (Pseudomonas) cepacia Xanthomonas (Pseudomonas) maltophilia Mycobacterium sp. Flavobacterium sp. Norcardia sp. Product r AJcalase/subtilisin 107 ------- By-product 2,4,5-Trichlorophenoxyacetate metabolites Pentachlorophenol metabolites Crude oil degradation metabolites 9 108 ------- References for Table 2. Pest Control Bacillus thuringiensis subsp. israelensis: Mayes, 1989; Held, 1986, Kawanishi, 1990 Bacillus thuringiensis subsp. kurstaki: Sherwood, 9191a, 1991b Pseudomonas syringae: Olenchock, 1988; Goodnow, 1990 Autographa californica: Hartig, 1989; Hartig, 1992 Biodegradation Pseudomonas sp.: Kaiser, 1981 P. aeruginosa: George, 1989,1990, 1993 P. putida: Kaiser, 1981 Burkholderia (Pseudomonas) cepacia: George, 1991, 1990 Xanthomonas (Pseudomonas) maltophilia: George 1989, 1990, 1993 Mycobacterium sp.: Kaiser, 1981 Flavobacterium sp.: Kaiser, 1981 Norcardia sp.: Kaiser, 1981 Product Alcalase/subtilisin: Sario, 1991; Sarlo, 1990 By-product 2,4,5-Trichlorophenoxyacetate metabolites; George, 1992 Pentachlorophenol metabolites: DeMarini, 1990 Crude oil degradation metabolites: Claxtori, 1991a; 1991b 109 ------- Table 3. Temperature range for survival of some bacterial species of biotechnology relevance. Biotechnology Agent Pseudomonas aeruginosa P. putida P. fluorescens P. aureofaciens P. syringae Temperature Optimum (°C)a 37 25-30 25-30 -30 -25-30 Burkholderia cepacia -30-35 Xanthomonas maltophilia 35 Bacillus thuringiensis B. subtilis B. popliae B. lentimorbis 30-40 (10-40)b 30-40 (10-50) -30 -30 Thiobacillus ferroxidans 30-35 (10-37) Sulfolobus sp. >50-87 Rhizobium meliloti 25-30 (4-42.5)b Bradyrhizobium japonicum 25-30 (25-42)b a Bergeys's Manual of Systematic Bacteriology, volume 1 (Krieg et al., 1984;, volume 2 (Sneath et al., 1986), and volume 3 (Staley et al., 1989) b Numbers in parentheses indicate temperature range. 110 ------- Table 4. Pathogenicity Factors identified in Pseudomonas and Burkholderia spp. Trait Pseudomonas aeruginosa Burkholderia cepacia Pseudomonas fluorescens Pseudomonas putida Protease X X X Exotoxin A X Elastase X X X Hemolysin X X Phospholipase C (Lecithinase) X (X) X Pyochelin X X Lipase X X X X Enterotoxin X Adhesins: Alginate/Mucoid polysaccharide X X Exoenzyme S X Pili/Fimbriae X X 111 ------- Table 4 references: Trait Pseudomonas aeruginosa Burkholderia cepacia Pseudomonas fluorescens Pseudomonas putida Protease Grimwood et al, 1989 Woods & Sokoi 1986 Liu Bevivino et al., 1994 Tan/Miller 1992 Wilson & Miles 1975 Exotoxin A Woods et al 1982 Woods et al 1991 Grimwood et al 1989 Woods & Sokol 1986 Elastase Woods et al 1982 Liu McKevitt Oakley et al, 1963 Hemolysin Woods/Sokol 1986 Liu Wilson & Miles 1975 Phospholipase C (Lecithinase) Grimwood 1989 Woods et al., 1991 Wilson & Miles 1975 Liu Esselman and Liu 1961 Collagenase Liu Pyochelin Woods etal., 1991 Bevivino et al 1994 Lipase Jorgensen 1991 Wolfarth 1992 Jorgensen 1991 Tan/Miller 1992 Wolfarth 1992 Wolfarth 1992 Enterotoxin Liu 112 ------- Adhesins: Alginate/Mucoid Marcus1989 Straus 1989 polysaccharide Liu Pedersen 1992 Exoenzyme S Woods/Que 1987 Woods et al 1991 Grimwood et al 1989 Woods Sokol 1986 Pili/Fimbriae Kuehn 1992 Ramphal Goldstein 1984 1995 Farinha 1994 Tang 1995 t 113 ------- Table 5. Use of bioassays to determine the toxicity of bioremediation processes and hazardous waste. Chemical Matrix Bioassay Reference PCB metabolites — Sister chromatid exchange Salmonella reversion Sayler 1982 Chlorophenols — Prophage induction (£. coll) DeMarini 1990 2,4,5-T — Salmonella reversion Prophage induction (£ coll) George 1992 Pesticide waste soil Salmonella reversion Somich 1990 Benzofajpyrene soil sludge Salmonella reversion Miller 1988 Wood preserving waste soil water MicrotoxTM Salmonella reversion Aspergillus nidulans Bacillus subtilis DNA-repair Aprill 1990 Donnelly 1987 a,b Petroleum waste soil Microtox™ Salmonella reversion Seed germination Plant Aprill 1990 Wang 1990 Hazardous waste complex mixture soil water Salmonella reverion SOS (E. coli umu) Prophage induction (E coli) Donnelly 1988 McDaniels 1993 Houk DeMarini 1988 114 ------- Table 6. Genetically engineered microorganisms documented to have caused an ecological effect and/or transmitted DNA to another organism (adapted from Seidler, 1992, Doyle, et al., 1995 ). Alcaligenes Alcaligenes eutrophusA E0106(pRO101) Degraded chlorinated phenols and transferred plasmid to indigenous bacteria; natural selection favors recipients tranisently altered the bacterial diversity of aquatic microcosm compared to uninoculated lake water Fulthorpe and Wyndham (1991) Nakatsu, et al., (1995) Leser (1 995) Enterobacter cloacae multiples, gene transfer inside insect gut Armstrong, et al. (1 990) Pseudomonas putida Pseudomonas sp. RC1 Degraded 3-chlorobenzoate and transferred degradative capacity to indigenous Pseudomonas sp. Reduced colonization of wheat rhizoplane by indigenous fluorescent pseudomonads, which help in suppressing take-all disease of wheat by the fungus Gaumannomyces graminis var. tritici Pertsova et al. (1984) Fredrickson et al. (1989) Pseudomonas sp. B13 gene transfer of 3-chlorobenzoate activity into Alcaligenes in a natural aquifer Zhou and Tiedje, (1995) 'This strain is not genetically engineered Pseudomonas putida PPO301 (pRROI 03) accumulates 2,4-dichlorophenol from 2,4-D degradation which reduces CO2 evolution from Doyle et al. soil and decreased number of fungal (1991); propagules in soil to undetectable Short et al. levels (1991) 115 ------- Pseudomonas cepacia AC100 Degraded 2,4,5-T; caused changes in taxonomic diversity of indigenous microbiota, possibly as Bej et al. a result of metabolic activity by the GMO (1891) Pseudomonas fluorescens P.fluorescens lux-modified denitrifier Pseudomonas aureofaciens Kmr, xylE, lacZY chromosomal modification plant growth promoting fluorescent pseudomonads plasmid DNA transferred to several genera of indigenous bacteria caused short term reduction in overall microbial diversity in very small pore size soil caused large perturbation (up to 100-fold) changes in microbial populations on seeds and root systems of spring wheat. Changes were transient but could still be detected in colony morphology differences when cultured from maturing plant roots unexpected dispersal to plant shoots following seed inoculation Smit, et al. (1991) White, et al. (1994) De-Leij, et al. (1 994) Raaijmakers, et al. (1995) Streptomyces lividans (TK23-3651 (pSE5) Increased transiently the CO2 from soil microcosms when lignocellulose was added (pSE5 codes for enhanced production of extracellular lignin peroxidase and H2O2; Wang, et al. (1991) Lactobacillus plantarum Recombinant strains containing a Clostridium thermocelium derived cellulose gene inoculated into grass minisilos sucessfully proliferated and competed with epiphytic lactic acid bacteria in silage Sharp, et al (1992) 116 ------- Agent/Product Species Strain Route Reference 28 K polypeptide of B. thuringiensis subsp. israelensis mouse rat rat Japanese Quail Swiss-Webster Sprague-Dawley CD i.p. oral i.p. i.p. s.c. i.v. oral i.p. s.c i.v. i.n. Roe Mayes 1989 Mayes 1989 Roe 1991 Roe Roe Roe Roe Roe Roe Roe B. thuringiensis subsp. israelensis mouse CD-1 i.n. i.t. Kawanishi 1990 B. thuringiensis subsp. kurstaki mouse CD-1 i.n. i.t. Kawanishi 1990 B. thuringiensis subsp. aizawai mouse CD-1 i.n. i.t. Kawanishi 1990 B. thuringiensis subsp. wuhanensis mouse CD-1 i.n. Sherwood 1991 P. syringae rat Sprague-Dawley inh. Goodnow 1990 P. putida rat Sprague-Dawley oral i.e. i.p. inh. Kaiser 1981 P. aeruginosa 1 mouse CD-1 C3H/HeJ oral i.n. i.n. George 1989 George 1991 George 1993 117 ------- B. cepacia mouse CD-1 oral i.n. George 1990 George 1991 X. maltophilia mouse CD-1 oral George C3H/HeJ i.n. 1989 George 1993 i.p,, intraperitoneal^; i.e., intracutaneous; s.c., subcutaneous; i.n., intranasal; i.t, intratracheal; i.v., intravenous. 118 ------- Figure 1. Degradation pathway for pentachlorophenol. 9 119 ------- CI CI xx CI CI CI CI C02+CH4 CI Pentachlorophenol CI 2,3,4,5" Tetrachlorophenol CI 3,4,5- Trichlorophenol 3,5- 3- Dichlorophenol Chlorophenol ------- LEVEL 1: STRUCTURE-ACTIVITY RELATIONSHIP • Literature Search • Discussions with Chemists/Biochemists ~ \ (+) H LEVEL 2: IN-VITRO REACTIVITY • Reactivity with Protein-Conjugate Formation ~ \ (+) H i LEVEL 3: IN-VIVO REACTIVITY-IMMUNOGENICITY • Guinea Pig Injection Model ~ \ (+) H LEVEL 4: IN-VIVO REACTIVITY-ALLERGENICITY 9 • Guinea Pig Inhalation Model Figure 2. Proposed multilevel approach for assessment of new chemicals as respiratory allergens. Positive results at one level should lead to further testing at the next level with the final test using the inhalation model. If a negative results is obtained at one level, then no further testing should be done with the chemical in question. ------- NHEERL-COR-2024A TECHNICAL REPORT DATA (Please read instructions on the reverse before completing) 1 REP0RTNE°P A/600/A-96/096 2. 3. RECIPIEf 4. TITLE AND SUBTITLE Assessing Risks from GMOs to Ecosystems and Human Health 5. REPORT DATE 6. PERFORMING ORGANIZATION CODE 7. AUTHOR(S) 'R. J. Seidler; 'L. S. Watrud; 2S. E. George 8. PERFORMING ORGANIZATION REPORT NO. 9. PERFORMING ORGANIZATION NAME AND ADDRESS 'U.S. EPA, NHEERL, Corvallis, OR 2U.S. EPA, NHEERL, Research Triangle Park, NC 10. PROGRAM ELEMENT NO. 11. CONTRACT/GRANT NO. 12. SPONSORING AGENCY NAME AND ADDRESS US EPA ENVIRONMENTAL RESEARCH LABORATORY 200 SW 35th Street Corvallis, OR 97333 13. TYPE OF REPORT AND PERIOD COVERED Symposium Paper 14. SPONSORING AGENCY CODE EPA/600/02 15. SUPPLEMENTARY NOTES Invited review article to appear in The Handbook of Environmental Risk Assessment 16. ABSTRACT Scientists have been altering the genetic makeup of living creatures since the 1970s. Techniques in molecular biology have made it possible to incorporate genes from one organism into virtually any other organism's genetic composition to create a broad array of new life forms. This manuscript is a literature review of the status of the field of assessing the health and ecosystem safety of genetically modified microorganisms (GMOs). 17. KEY WORDS AND DOCUMENT ANALYSIS a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group genetically engineering organism, risk assessment, health effects, environmental effects 18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This Report) 21. NO. OF PAGES 121 20. SECURITY CLASS (This page) 22. PRICE EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE ------- |