by Peter Olson BA. Dip Ed. Original version published in The Village Journal, NSW, Australia.

-Genetically modified (GM) crops often contain a bacterium called Bacillus Thuringiensis (Bt).

-Most of the research on Bt has looked at the directly lethal affects of Bt and little research has looked for indirectly lethal affects the Bt.

-Some insects have been shown to survive the Bt poison by having a strong immune response to the Bt poison. (Ref R)

– Insects generally and Bees specifically, have been shown to experience learning impairment and memory disorder, if they have an immune response.(Ref A1, B, D, E)

-A learning impairment or memory disorder would mean that Bees could not navigate back to their beehive.

-Thus, a learning impairment or memory disorder is lethal to a foraging Bee.

-Colony Collapse Disorder (CCD) of Bees, was originally called Fall Dwindle Disease, meaning the disease occurred in the cold months of the year.

-Bees use protein to construct a memory and their protein comes from pollen, but in winter there is no pollen.

-Bees also use protein to achieve an immune response, so an immune response in winter, means all protein reserves are rapidly used up and none are left for memory formation. (Ref D)

Have you ever noticed that when you are sick, that you can’t think quickly and clearly? It’s a bee gets sick and can’t think probably, it will not be able to return to its beehive.

Studies listed below show that learning in bumblebees is impaired, if the bumblebee has an immune response (Ref A1,B,D,E).

The insecticide Bt is incorporated into many genetically modified crops and Bt causes an immune response to a wide range of creatures in nature, even if it does not kill those creatures. (Ref Q,R,S)

It is a virtual certainty that the bumblebee does have an immune response to the Bt present in the pollen of genetically modified plants.

Bees only carry enough honey with them to fly directly to the target flowers and straight back to the beehive. The navigation to and from those flowers is extremely complex and so requires the bee to have a very good memory. Since learning and memory are impaired in bees that have an immune response, bees with an immune response get lost, run out of honey fuel, fall to the ground and are then are carried away by ants. Thus, if a bee gets lost, for even a few minutes, it is dead.

The Encyclopedia Britannica states of CCD that, “it appears that the disorder affects the adult bees’ ability to navigate”. (Ref Y)

Thus suggesting that worker bees fly out from the high hive to collect food, but get lost and never return.

In the case of the viruses and pathogens that have been suggested as causes of CCD, those viruses and pathogens result in large numbers of dead bees either inside or outside of the beehive. Dead bees are found outside the hive, because worker bees carry dead bees outside. In CCD, the symptoms are that no dead bees are found inside or outside the beehive, rather all the “worker bees from a beehive or European honey bee colony abruptly disappear” (Ref V).

One of the most common traits inserted into man-made genetically modified crops is resistance to caterpillars, which is given by inserting a gene for a naturally occurring insecticidal bacterium called Bacillus thuringiensis (Bt). In crops that are genetically modified to contain this Bt gene, the Bt will be present not only in the plants leaves and fruit but also in the pollen of the flowers. Thus Bees that take pollen from genetically modified crops are ingesting significant quantities of Bt insecticide. Many scientists have assured the public that Bt is safe, because Bt is not directly lethal to Bees. However alcohol is also not directly lethal to a car driver, yet many car drivers have died from alcohol, even though alcohol is not directly lethal to a car driver. Scientists looking for a cause for CCD have generally looked for a direct cause, something such as virus or parasite, that is directly killing the bees. Discovering an indirect cause of mortality in bees, would be much more difficult and would only occur after scientists had first exhausted examining the most probable direct causes of mortality in bees. A review of the literature shows that at the time of writing, according to Cox Foster et al 2009, “no single culprit has been identified” as the cause of CCD (Ref Z3).

German research (Ref C), showed that bees who were fed Bt were not killed by the Bt, but that they became greatly more susceptible to a subsequent disease challenge. The Jenna University study showed that mortality in Bees exposed to a parasite, was far greater in Bees that had previously been fed BT, compared to Bees that were not previously fed BT (Ref C). Meaning that BT increased the susceptibility of Bees to the pathogen and thus Bt multiplied the mortality caused by the pathogen. In regard to that increased mortality from a pathogen combined with Bt ingestion, the authors concluded, “the significant differences indicate an interaction of toxin and pathogen on the epithelial cells of the honeybee intestine. The underlying mechanism which causes this effect is unknown” (Ref C). This is a highly significant finding because when GM crops containing BT were being approved, the universal assumption was, that GM crops containing Bt would be totally safe, because Bt has no effect on bees. Thus government scientists who approved GM Bt crops, would clearly have objected to those crops, if they thought that GM crops containing Bt would adversely affect bees.

In the USA, Cox Foster et. al. state of the CCD bee colonies that they studied, “we hypothesized that something had compromised the bees’ immune system, making them susceptible to any number of infections that healthy colonies would normally fend off” (Ref Z3). This sounds quite similar to the Jenna University findings above. Furthermore, Cox Foster et. al. note that their Bee autopsies found symptoms never observed before, such as scar tissue in the internal organs (Ref Z3).

Bt is a living bacterium, that forms crystals of proteinaceous insecticidal endotoxins, whose mode of action is to form a pore or hole in the insect’s gut cell membranes (Ref Z2). Since the mode of action of BT is to damage the gut lining and since Cox Foster et al. found scar tissue in the internal organs of Bees, the question must be asked, was the damage to the internal organs of Bees that Cox Foster et. al. found, caused by the Bt in the pollen of GM crops, that the bees ate? Cox Foster et al. 2006 noted during the autopsies, “when wet mounts were examined they appeared to have crystalline arrays” and that “Crystal-like formations were observed in the thorax”(Ref Z4). Bt toxins are crystalline.

Cox Foster et al. 2009, did consider the possibility that bees with CCD may have been poisoned by pollen from genetically modified crops. However the authors refer to earlier research, showing that the Bt toxin is only activated in certain insects and they note that the Bt toxin does not work in the digestive tracts of honeybees (Ref Z3). Thus because of prior research showing that bees are not killed by Bt, and that BT cannot possibly effect bees, many bee scientists have avoided testing Bt on Bees, believing such testing has already taken place and have thus ruled out GM Bt as possible cause of CCD of Bees.The online encyclopedia Wikipedia takes a very different view however and does list GM crops as a possible cause of CCD (Ref V).

Testing for subtle, sublethal effects or synergistic affects of Bt with other organisms, where Bt is a cofactor, rather than a singular causative agent, has only been done recently. Where such testing has been done, the finding of sublethal effects or cofactor effects, was often by chance, rather than planned. It was only by chance that the bees in the above mentioned Jena University study became infected with a parasite and thus only by chance that the scientists observed the synergistic effect, of combining a pathogen and Bt. The results of a growing number of studies, now show clear and substantial, nonlethal effects and cofactor affects, of Bt on Bees; a dramatic change from the previous scientific view, that Bt has no effect on Bees.

Even so, the nonlethal effects and cofactor affects of Bt on Bees still remain scantily studied and more research on these subtle kinds of affects is urgently required.

Ramirez et. al. 2008, tested Bt toxin on honeybees and discovered substantial nonlethal affects on the bees, including “disturbed learning performances”. Ramirez et al. concluded “Our results show that transgenic crops expressing (Bt) Cry1Ab protein at 5,000ppb may affect food consumption or learning processes” in Bees (Ref B).

The honeybee depends upon an unusual array of complex learning processes, in order to successfully find its food and navigate back to the beehive. Unlike a car driver who may not remember exactly where the car is parked, in a large parking lot and who can afford to take some time to find the car, the honeybee cannot afford to forget, even for a short time, exactly where the beehive is located, even if the hive is several miles away. Memory impairment is not lethal to humans, but memory impairment and learning impairment is indeed lethal to honeybees. Thus in addition to causing increased disease susceptibility, BT is also shown to produce cognitive impairment in Bees.

It is important to note that BT is not the only insecticidal that has been shown to cause cognitive impairment in Bees. Cox Foster et al. mentioned in 2006, that Neonicotinoid insecticides can produce sublethal effects, such as learning impairment and that as a result of a such learning impairment, Bees “may not be able to learn the location of the hive” (Ref Z4) and may thus may be unable to navigate back to the hive. So one can now see, a proven trend, of learning impairment in Bees, caused by insecticide exposure at a sublethal dose. Cox Foster et al. 2006 clearly state what happens when Bees eat pollen contaminated with sublethal doses of neonicotinoid insecticides. “If bees are eating fresh or stored pollen contaminated with these chemicals at low levels, they may not cause mortality but may impact the bee’s ability to learn or make memories” (Ref Z4). That sounds very similar to the above reference from Ramirez et al. 2008 who found “disturbed learning performances” in Bees after consumption of GM Bt pollen (Ref B). So the learning impairment in Bees, induced by consumption of insecticidal GM Bt pollen, can be seen as part of a larger trend for sublethal doses of certain insecticides, to produce learning impairment in Bees.

The difference between a neonicotinoid insecticide spray and the Bt insecticide in a genetically modified crop, is that the former is very easy to restrict or recall, whereas the latter may prove impossible to recall. With genetic materials, the quantity of GM material in existence gets bigger as time passes. If a problem develops with a GM crop, then that problem will likely increase as time passes.

The fact that CCD can be transmitted by beehive equipment could be to do the presence of the Bt bacterium in that beehive equipment and and the fact that Cox Foster et. al. were able to break the cycle of CCD by irradiating the beehive equipment (Ref Z) and restocking with a new supply of Bees, could be due to the fact that the Bt bacterium was killed by the irradiation.

In order to understand CCD, or the disappearance of bees, one needs to understand something about the specialised lifestyle of the bee. In order to save weight and increase performance, bees only carry enough fuel (honey) to fly directly to the target flowers and then straight back to the beehive. If a bee gets lost, or encounters unexpected head-winds, it will not have enough fuel reserves to make it back to the beehive. Instead it will fall to the ground and die. Ants will then carry the dead bee down into the ant nest.

Memory is also crucial to bees because a bee has to learn from other bees in the beehive, where the target flowers are located. The Bee must memorise the directions from the hive to the target flower and back again, so a perfect memory is essential for the survival of bees. Other insects like mosquitos are less reliant on a good memory, and simply “follow their nose” to the food – whereas bees rely on memorising complex navigation tasks and memorising specific aromas (Ref F), to find specific food and then to find their way back to the beehive. If one was to impair the learning or memorising ability of bees, that would cause indirect mortality in bees, since they would not be able to find their way back to the hive.

GM Bt pollen is widely known not to kill bees directly, but was not tested prior to the release of GM Bt crops, for the ability of GM Bt pollen to kill bees indirectly, through impairing the memory of Bees.

There is scientific agreement that many different things can be lethal to Bees – such as disease, chemical sprays and even certain seed coatings.

In the Flour Moth Ephestia kuehniella, a non lethal response to Bt and “tolerance (of Bt) correlates with an elevated immune response” to the Bt. (Ref R). For 99.99 percent of creatures, such a non-lethal immune response to Bt is of no practical significance and because of this, Bt is referred to as “soft” and is used widely in organic agriculture. There is however one particular species that is very unusual, in that it has a life threatening response, to sub-lethal immune stimulation (Refs ,B,D,E) and that species is the Bee. Immune response in Bees, can lead to memory loss and learning impairment (Ref B,D,E) and as previously stated, loss of memory would cause bees to forget where the beehive is located. Bees are insects and an “immune response inhibits associative learning in insects” (Ref E). Bees are now eating GM Bt pollen and Bt is toxin known to cause a non-lethal immune response in a wide variety of creatures (Ref Q,R,S).

Bees use up protein in memory formation and they also use up protein if they have an immune response (Ref D). Bees only protein source is pollen and if pollen is in short supply and bees have an immune response, they will use all available protein for the immune response, leaving none available for memory formation (Ref D). Pollen for bees is in short supply during Autumn and Winter, so if bees have an immune response when pollen is in short supply, they will lose their memory (Ref D). CCD was originally called Fall Dwindle Disease, meaning loss of bees in the Autumn, when pollen from flowers is in short supply. If bees loose their memory, they lose their navigational skills, they fail to find their way back to the beehive, they fall to the ground, die and get carried away by ants and are never seen again. As mentioned above, the loss of memory due to an immune response, is not confined to Bees, but occurs in insects generally. “The cost of an immune response (in insects) therefore not only affects survival of the host…. but also everyday behaviour and memory formation” (Ref E). This learning impairment was only discovered recently (Ref E), long after GM crops had already been planted, however the effects of the GM Bt crops will go on for millions of years, since, like other introduced foreign species, GM crops can not be recalled.

During discussions with various Bee scientists, the writer was unable to find any scientist who had ever heard that insects and Bees loose their memory if they have an immune response. Perhaps the reason they did not know, is because the discovery of an immune – memory relationship in insects is very recent. There is no evidence of direct mortality in bees from exposure to GM Bt crops, yet there is substantial evidence of sub-lethal effects in Bees from such exposure, that can result in high indirect mortality of Bees. If every air plane pilot had a sudden, non-lethal lapse of memory, there would be chaos which could cause in high mortality. Similar chaos occurs for Bees if they have a sudden lapse in memory, caused by an immune response and coincident pollen protein deprivation (Ref D).

When speaking to a PhD at a Gene Regulator’s office, that PhD scientist described some of the information herein as “new” and not previously known by that Gene Regulator. Scientists that wish to defend GM Bt crops, need to counter the proven scientific evidence of indirect mortality in Bees that is provided herein, rather than simply stating that GM Bt pollen is not directly lethal to Bees.

Bt toxins produce sub-lethal effects in Bees and those sub-lethal effects result in changes in the Bee’s “feeding behaviour”, “learning processes” and “foraging efficiency” (Ref B). Behaviour change is evidence of learning impairment, and learning impairment can lead to lethal situations for Bees in the field – navigation problems and reduced flower finding abilities (Ref F), which are dependent on a perfect memory.

The different kinds of toxic GM Bt crystalline proteins are designated with different letters; Cry1A, Cry2A, Cry3A, etc. Scientists in Mexico discovered that “the Bt toxin Cry1Ab caused reduced foraging activity in bees after they were fed with syrup containing the toxin” (Refs A, A1). Something new is being put into the Bee’s environment; something which is herein shown to impair the Bees functions and to increase their mortality from diseases such as parasites (Ref C). Bees do not simply go out and look for any flower. They learn and memorise the aroma and location of a specific flower while in the hive, then they fly directly to that specific flower’s location (Ref F). Memory impairment would thus prevent Bees from finding a specific flower’s location and similarly prevent Bees successful return to the hive.

It is crucial to understand that with CCD, dead Bees are seldom found in or near the hive. When Bees are attacked by the lethal Bee mite, “thousands of dead bees will pile in front of the hive” (Ref U), as a result of infestation. In the case of CCD however, few if any dead Bees are ever found in or around the hive. Hence although Varroa mite is a serious disease of Bees, its symptoms do not match the symptoms of CCD. Also, the timing of Varroa mite infestation does not match the timing of CCD appearance. Varroa first entered Japan in 1960’s, Brazil in 1971, France in 1982 and the USA in 1987 (Ref T), but CCD was first noticed in USA around 2004, and in Europe about 2006, many, many years after Varroa arrived, but only shortly after GM crops were widely planted. The writer does not wish to rule out other possible causes for CCD, because the intent is to simply demonstrate that GM Bt crops may harm Bees, regardless of wether they are the sole cause CCD or not. It took decades to show that cigarette smoking was harmful and it could take just as long to gain consensus over the cause of CCD. It is simpler to suggest GM Bt pollen causes Bee memory loss (Ref D,E). That memory loss occurs when Bees have an immune response and are deprived of pollen (Ref D).

The German Speigel article states that the bacterial toxin in the genetically modified corn may have “altered the surface of the bee’s intestines, sufficiently weakening the bees to allow the parasites to gain entry” (Ref C). Wikipedia says that the mode of action of Bt through making pores or holes in the gut lining (Ref T) and such holes caused by Bt, would obviously allow the parasites a new and easy pathway into the Bee. Is it not logical, that Bt exposure in the wild, would cause a similar, significant increase in mortality from parasites, like Microsporidia, just as it did in the trials (Refs A2, C)?

Bees are a key species for human food supply and bio-diversity and several lethal risks to Bees from GM Bt pollen are demonstrated here.

Britain’s chief scientist Sir David King, once proudly stated that Genetically Modified (GM) crops “could solve third world hunger”. Later he admitted that his claim was wrong (Ref M) and in fact the real outcome would appear to have been the exact opposite of his prediction. Now that GM crops have been widely planted and hence can not be recalled, we learn that GM crops actually produce significantly lower yields than natural varieties do. A large American study showed that “modified soya produces 10 per cent less food than its conventional equivalent” (Ref O).


Peter Olson BA. Dip Ed.
Author can be contacted at:


NB: References with a PMID number can be found at the US National Library of Medicine website below, by simply typing the PMID number in the search box and hitting the enter key.

Ref A.

ISIS Press Release 26/04/07

Dr. Mae-Wan Ho and Prof. Joe Cummins (Ontario Univesity)

Mystery of Disappearing Honeybees – Quote: “The Bt toxin Cry1Ab caused reduced foraging activity in bees after they were fed with syrup containing the toxin”

Ref A1

Ramirez-Romero R, Chaufaux J and Pham-Delègue M.

Effects of Cry1Ab protoxin, deltamethrin and imidacloprid on the foraging activity and the learning performances of the honeybee Apis mellifera, a comparative approach Apidologie 2005, 36, 601-11.

Ref A2

The effects of Bt maize pollen on the honeybee, 2001-2004 Jena University, GMO Safety, Federal Minstry of Education and Research,

Ref B.

Ecotoxicol Environ Saf. 2008 Jan 16

Does Cry1Ab protein affect learning performances of the honey bee Apis mellifera L. (Hymenoptera, Apidae)?

Ramirez-Romero R, Desneux N, Decourtye A, Chaffiol A, Pham-Delègue MH.

Instituto de Ecologia A.C., Km. 2.5 Carretera Antigua a Coatepec No. 351 El Haya, 91070 Xalapa, Veracruz, Mexico.

The tested concentrations of Cry1Ab protein did not cause lethal effects on honey bees. However, honey bee feeding behaviour was affected when exposed to the highest concentration of Cry1Ab protein, with honey bees taking longer to imbibe the contaminated syrup. Moreover, honey bees exposed to 5000ppb of Cry1Ab had disturbed learning performances. Our results show that transgenic crops expressing Cry1Ab protein at 5000ppb may affect food consumption or learning processes and thereby may impact honey bee foraging efficiency.

PMID: 18206234 [PubMed – as supplied by publisher]

Ref C.,1518,473166,00.html

University of Jena, Germany, 2004

Spiegel Online International: March 22, 2007


Are GM Crops Killing Bees?

By Gunther Latsch

quote: “when, by sheer chance, the bees used in the experiments were infested with a parasite………a “significantly stronger decline in the number of bees” occurred among the insects that had been fed a highly concentrated Bt poison feed.”

According to Hans-Hinrich Kaatz, a professor at the University of Halle in eastern Germany and the director of the study, the bacterial toxin in the genetically modified corn may have “altered the surface of the bee’s intestines, sufficiently weakening the bees to allow the parasites to gain entry –…”

Ref D

Brain Behav Immun. 2006 Mar;20(2):135-8. Epub 2005 Aug 9.

Insect psychoneuroimmunology: immune response reduces learning in protein starved bumblebees (Bombus terrestris).

Riddell CE, Mallon EB.

Department of Biology, University of Leicester, UK.

There is evidence that protein is intricately involved as this immune induced reduction in memory only becomes apparent after the bees are deprived of pollen (their only protein sources)”.

PMID: 16084688 [PubMed – indexed for MEDLINE]

Ref E

Proc Biol Sci. 2003 Dec 7;270(1532):2471-3.

Immune response inhibits associative learning in insects.

Mallon EB, Brockmann A, Schmid-Hempel P.

Ecology and Evolution, ETH Zürich, ETH-Zentrum NW, CH-8092 Zürich, Switzerland.

Here, we present behavioural evidence indicating a link between the

immune system and the nervous system in insects. The cost of an immune response therefore not only affects survival of the host, as previously shown, but also everyday behaviour and memory formation.

PMID: 14667337 [PubMed – indexed for MEDLINE]

Related Links

Insect psychoneuroimmunology: immune response reduces learning in protein starved bumblebees (Bombus terrestris). [Brain Behav Immun. 2006] PMID:16084688

Ref F

Social learning of floral odours inside the honeybee hive. [Proc Biol Sci. 2005]


Ref G

Science and Development Network News

Mexico confirms GM maize contamination

Katie Mantell 19 April 2002

Quote: The Mexican government has confirmed earlier reports that transgenic maize is growing within the country’s borders and has apparently contaminated wild varieties, despite a national ban on the cultivation of genetically modified (GM) crops. A government-commissioned study has shown that as many as 95 per cent of maize fields in the Mexican states of Oaxaca and Pueblo contain evidence of GM ‘contamination’.

Ref H

Lateral gene transfer (LGT), is any process in which an organism transfers genetic material to another cell that is not its offspring.

Ref I

The only human clinical trial showed that transgenes from soy transfer into intestinal bacteria.

Netherwood, et al (2 February 2004) Assessing the survival of transgenic plant DNA in the human gastrointestinal tract, Nature Biotechnology, Vol 22 Number.

Ref J

Nature,November 29 issue 2001,

David Quist and Ignacio Chapela, University of California

Quote: “showed that DNA from GM maize had been found in wild varieties” Lateral Gene Transfer.

Ref K

Proc Natl Acad Sci U S A. 2007 Oct 9;104(41):16204-8. Epub 2007 Oct 8.

Toxins in transgenic crop byproducts may affect headwater stream ecosystems.

Rosi-Marshall EJ, Tank JL, Royer TV, Whiles MR, Evans-White M, Chambers C,

Griffiths NA, Pokelsek J, Stephen ML.

Department of Biology, Loyola University Chicago, Chicago, IL 60626, USA.

We show that corn byproducts, such as pollen and detritus, enter headwater streams and are subject to storage, consumption, and transport to downstream water bodies Laboratory feeding trials showed that consumption of Bt corn byproducts reduced growth and increased mortality of nontarget stream insects. Stream insects areimportant prey for aquatic and riparian predators, and widespread planting of Bt crops has unexpected ecosystem-scale consequences.

PMID: 17923672 [PubMed – indexed for MEDLINE]

Ref L

Department of Horticulture and Landscape Architecture

Purdue University, West Lafayette, IN USA


Scientist who claimed GM crops could solve Third World hunger admits he got it wrong

18 December 2007

Ref O

The Independent. Exposed: the great GM crops myth

Jeoffrey Lean 20/04/2008

Ref Q

Mol Immunol. 2007 Feb;44(6):1209-17. Epub 2006 Aug 22.

Analysis of the cellular immune response induced by Bacillus thuringiensis Cry1A

toxins in mice: effect of the hydrophobic motif from diphtheria toxin.

Guerrero GG, Russell WM, Moreno-Fierros L.

Universidad Nacional de México.

Insecticidal Cry1A toxins from Bacillus thuringiensis elicit strong humoral

immune response in mice.

PMID: 16930715 [PubMed – indexed for MEDLINE]

Ref R.

Proc Natl Acad Sci U S A. 2004 March 2; 101(9): 2696-2699.

Published online 2004 February 20.

Quote: We present evidence that tolerance to a Bt formulation in a laboratory

colony of the flour moth /Ephestia kuehniella/ can be induced ….. and that the

tolerance correlates with an elevated immune response.

Ref S

Environmental Health Perspectives Volume 107, Number 7, July 1999

Immune Responses in Farm Workers after Exposure to Bacillus Thuringiensis Pesticides

Leonard Bernstein, Jonathan A. Bernstein, Maureen Miller, Sylva Tierzieva,1 David I. Bernstein, Division of Immunology, Department of Internal Medicine, University of Cincinnati, USA. Quote: Exposure to Bt sprays may lead to allergic skin sensitization and induction of IgE and IgG antibodies

Ref T

Ref U

Dr. James E. Tew, Associate Professor of Entomology, Beekeeping Consultant

quote: Colonies can die so fast from high Varroa infestations that

thousands of dead bees will pile in front of the hive.

Ref V

Ref W

Ref X

Ref Y

Ref Z

Science 12 October 2007:Vol. 318. no. 5848, pp. 283 – 287

A Metagenomic Survey of Microbes in Honey Bee Colony Collapse Disorder

Diana L. Cox-Foster Et Al

Ref Z2

Ref Z3

Solving the Mystery of the Vanishing Bees

Scientific American Magazine – March 31, 2009

Cox-Foster D. and vanEngelsdorp D.

Ref Z4

Fall Dwindle Disease: A preliminary report

December 15, 2006 Dennis vanEngelsdorp, Diana Cox Foster, Maryann Frazier, Nancy Ostiguy, Jerry Hayes,

CCD Working Group, The Pennsylvania State University


One response to this post.

  1. Notable scientists admit that genetically engineered foods can create novel toxins or allergens. Ecosystem


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