Comparative Analysis of Genetically-Modified Crops: Conditional Equivalence Criteria

AbstractThe comparative assessment of genetically-modified (GM) crops relies on the principle of substantial equivalence, which states that such products should be compared to conventional counterparts that have an established history of safe use. In an effort to operationalize this principle, the GMO Panel of the European Food Safety Authority proposed an equivalence test that directly compares a GM test variety with a set of unrelated, conventionally-bred reference varieties with part of the difference as the known background of the test (the same as the given control). The criterion of the EFSA test, however, is defined solely by genotypic differences between the non-traited control and reference varieties (i.e. the background effect) while assuming the so-called GM trait effect as zero. As the outcome of an EFSA equivalence test is determined primarily by the similarity, or lack thereof, of the control and references, a conditional equivalence criterion is proposed in this investigation that focuses on “unintended” effects of a GM trait which is irrespective of the (random) genotypic value of a given control. The new criterion also includes a mean-scaled standard similar to the 80-125% rule for bioequivalence assessment practiced in the pharmaceutical industry as an alternative when the reference variation is zero or close to zero. In addition, optional criteria are proposed with a step-wise procedure to control the rate of false negatives (non-equivalence by chance) providing a comprehensive assessment under multiple comparisons. An application to maize grain composition data demonstrates that the conditional equivalence criterion provides effect-specific and more robust assessment of equivalence than the EFSA criterion did, especially for GM traits showing negligible or no unintended effects which are likely true for most traits in the current market.