"Comments on the human health impact of Bacillus thuringiensis toxin gene product in genetically modified crops"

EPA Review Docket Number OPP-00678B

Professor Joe Cummins
Professor Emeritus of Genetics
University of Western Ontario


I have studied the Environment Protection Agency (EPA) document "Bt Plant-Pesticides Biopesticides Registration Action Document B. HUMAN HEALTH ASSESSMENT" and comment in the following areas.

First, there is evidence that Bacillus thuringirnsis (Bt) cry 1 toxin will impact directly on human health through damage to the ileum , second , the use of synthetic Bt cry toxin genes has not been proven to be equivalent to the natural bacterial gene and finally, the introduction of natural and synthetic bacterial genes into crops and food sources for human or farm animals has not been evaluated regarding its introduction of high levels of the bacterial CpG trigger that activated the innate immune response. The study below shows that Bt Cry 1 toxin which is used extensively in corn and cotton products (oil and seed meal) used in human and animal food damages the mammalian ileum. Damage to the ileum can produce chronic illness such as fecal incontinence and/or flu like upsets of the digestive system. A brief description of the ileum and its function follows the article abstract.

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