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