unstable and prone to transfer again to unrelated species; potentially to all species interacting with the GMO(44). 17. The instability of transgenic DNA in GM plants is well-known(45). GM genes are often silenced, but loss of part or all of the transgenic DNA also occurs, even during later generations of propagation(46). We are aware of no published evidence for the long term stability of GM inserts in terms of structure or location in the plant genome in any of the GM lines already commercialized or undergoing field trials. 18. The potential hazards of horizontal transfer of GM genes include the spread of antibiotic resistance genes to pathogens, the generation of new viruses and bacteria that cause disease and mutations due to the random insertion of foreign DNA, some of which may lead to cancer in mammalian cells(47). The ability of the CaMV promoter to function in all species including human beings is particularly relevant to the potential hazards of horizontal gene transfer. 19. The possibility for naked or free DNA to be taken up by mammalian cells is explicitly mentioned in the US Food and Drug Administration (FDA) draft guidance to industry on antibiotic resistance marker genes(48). In commenting on the FDA's document, the UK MAFF pointed out that transgenic DNA may be transferred not just by ingestion, but by contact with plant dust and air-borne pollen during farm work and food processing(49). This warning is all the more significant with the recent report from Jena University in Germany that