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Monsanto Company Confidential
Topical Application of dsRNA for Pest Management
Greg Watson, PhD Monsanto Chemistry and Seed Regulatory SFIREG Policy and Other Matters Meeting September 20, 2016
Monsanto Company Confidential
Today’s Goals and Proposed Discussion Outline
Goals Engage with state regulators to initiate a dialogue Outline Basics of RNAi and potential for dsRNA-based products
Overview - RNA history of safe use: dietary safety, environmental fate, and ecological safety • Examples of approach to inform problem formulation and risk
assessment
Short introduction to the Bee Health Varroa and Canola Flea Beetle projects
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Monsanto Company Confidential
BioDirect ™ is Based on New Applications of dsRNA-based Technology
RNAi is a Natural Mechanism to Control the Expression of a Gene
DNA
Gen
e
RNA
Protein Produced
DNA
Gen
e
RNA
“Transfers information from gene to construct a protein”
Cells make small RNAs that specifically target
mRNA
RNA broken up Protein
Protein production reduced
“Oligo”
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dsRNA
Monsanto Company Confidential
PlantproducestheRNA
TworoutestouseofdsRNA-basedproductsincropimprovementTopically
applytheRNA
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Leading BioDirect™ projects: Varroa mite / managed honey bees Canola Flea Beetle
Corn Rootworm 3 (CRW3) Expresses DvSnf7 RNA
BioDirect™ projects in early stages of
Development - small scale efficacy testing to determine
potential for pest control
Monsanto Company Confidential
Regulatory Considerations for BioDirect • RNA-based suppression is a naturally occurring process, and is the basis for many desired phenotypes
• RNA-based technologies offer new modes of action in managing hard to control pests and viruses
• RNA has a history of safe consumption
• RNA offers specific gene suppression that greatly reduces potential impact on non-target organisms (NTOs)
• The current safety assessment strategy for exogenously applied RNA-based products is based on the same safety assessment paradigm used for other biological products
RNA is in food
Natural process
Favorable NTO profile
Existing paradigm is adequate
Additional tool
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Monsanto Company Confidential
Ø Core guideline studies to demonstrate lack of hazard Ø Ecological problem formulation and use of data / risk
assessment framework
The existing paradigm for dietary and environmental safety is robust and utilizes a number of endpoints to evaluate product safety:
Existing Regulatory Paradigm for Biopesticides is Appropriate for dsRNA based products
‘Consistent with section 408(b)(2)(D) of the FFDCA, EPA has reviewed the available scientific data and other relevant
information in support of this action and considered its validity, completeness and reliability and the relationship of this
information to human risk. EPA has also considered available information concerning the variability of the sensitivities of
major identifiable subgroups of consumers, including infants and children. The following information was used in a
weight of the evidence approach to show the absence of any dietary hazard associated with
DvSnf7 RNA.’ EPA Attachment #5, SAP Public Docket
CRW3 Human Health Assessment August 16, 2016 6
Monsanto Company Confidential
RNAi-based traits are common in nature, not new to agriculture
Tutejaetal.(2004)PlantCell16:19-35
Kosekietal.(2005)PlantCellPhysiol.46:1879-1883
DellaVedovaetal.(2005)GeneMcs170:1989-2002
Chalcone Synthase Suppression: • Soybean seed color • Maize stalk color • Star pattern in petunias
RNAi Mediates Other Natural Phenotypes: • Low glutelin rice • Viral and pathogen resistance
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Monsanto Company Confidential
Flavr Savr™ tomato Virus resistance Soybean oil
composition Quality Traits
Calgene 1994/1995
(USA, CAN, MEX)
• Squash 1994 (USA, CAN) • Papaya 1996 (USA, CAN) • Potato 1998 - 2002
(USA, CAN, MEX, AUS/NZ, JAP, RUS, ROM)
• Plum 2007 (USA) • Common Bean 2011 (BRA)
DuPont 1997/2011 (CHN, USA, CAN, MEX,
AUS, NZ, JAP, KOR, TWN)
Monsanto 2011/2012 (USA, CAN, MEX, AUS,
NZ, JAP, KOR, COL)
BASF amylopectin
potato 2010 (EU)
Simplot
Innate™ potato 2014 (USA)
Okanagan
Arctic® Apple 2014 (USA, CAN)
Monsanto
Reduced Lignin Alfalfa
2014-2016 (USA, CAN, MEX,
AUS, NZ, JAP, KOR)
RNAi is not new to agriculture Registered products mainly focus on virus resistance, compositional and quality traits
Monsanto CRW3 for Insect Control Expresses DvSnf7 RNA transcript targeting western corn rootworm
(Diabrotica virgifera) 2014-2016: USA, CAN, MEX, AUS, NZ, TWN, JAP (stage 3), ARG , KOR
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Monsanto Company Confidential
dsRNA-based products at State Level: Like other biopesticides
• EPA OPP BPPD data reviews and risk assessment • Biopesticide Registration Action Document
(BRAD) • EPA OPP Proposed registration decision public comment period • EPA OPP BPPD approved label • Active ingredient content, precautionary
language, and directions for use • State application for registration • For data reviewing states - Biochemical biopesticide dataset
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Monsanto Company Confidential
Barriers Limit Uptake of Ingested dsRNA
Systemic Barriers q Saliva q Stomach acid q Pancreatic nucleases q Intestinal epithelium q Vascular endothelium q Blood/systemic
nucleases
Cellular Barriers q Plasma membrane q Endosomal sequestration q Lysosomal degradation
9 Monsanto Company
Petrick, J.S. et al., (2013) Reg. Toxicol. Pharm., 66, 167-176
Monsanto Company Confidential
� RNA in its many forms is a common part of diets from both plant and animal sources
(Ivashuta, et al., 2009; Jensen, et al., 2013; Petrick et al., 2013) � Multiple studies looking for the uptake of RNA from food have
failed to find significant presence and regulation in mammals (Witwer et al, 2013; Snow et al., 2013; Dickinson et al., 2013; Tosar et al., 2014)
RNAhasafavorableprofileformammalianconsumers
Manybarrierscontributetoprotec0on
X
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Monsanto Company Confidential
Multiple Interdependent Factors Play a Role in Assessing RNA Ecological Risk
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Monsanto Company Confidential
®
Pollen Grain
Soil
Early studies show degradation comparable or better than Bt-proteins
� dsRNA can be accurately measured and evaluated from a variety of sources
� dsRNA quickly degrades (less than 24 hours in soil, 96 hours in surface water : sediment, ~72 hours in hives)
Hive Armstrongetal.(2013)JAg&FoodChemistry61:12557Dubelmanetal.(2014)PLoSONE9:e93155Fischer,etal.(2016)EnvTox&Chemdoi:10.1002/etc.3585Garbian,etal.(2012)PLoSPath8:e1003035
RNA has a favorable environmental profile
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Monsanto Company Confidential
Barriers and Differential Taxonomic Responsiveness Limit Potential Invertebrate NTO Hazard Extremely high concentrations of dsRNAs are required to elicit a RNAi phenotype in insect Orders outside Coleoptera1, 2
In some insect Orders barriers to efficacious RNAi-mediated insect control can include: • Salivary, midgut, and hemolymph
nucleases that rapidly degrade dsRNA3,4
• Inefficient uptake by midgut epithelial cells
• Length of dsRNA (e.g. ≥ 60 nts) required for uptake5
14 1.Huvenne, H. and G. Smagghe. 2010.; 2. Baum, J.A. and J. Roberts. 2014.; 3. Allen M.L. and W.B. Walker. 2012; 4. Garbutt, J.S. et al., 2013.; 5. Bolognesi R., et al. 2012.
Monsanto Company Confidential
Velez et al. (2015) Further Supports Lack of Responsiveness of Honey Bees to Environmental dsRNA
Honey bee larval development, adult eclosion, and adult survival were unaffected by D. virgifera and A. mellifera dsRNA targeting v-ATPase (with 21mer alignments)
Exposure at very high levels; 1µg/individual or 1000x the reported LC50 for WCR
Velez A., et al 2015 Chemosphere. 144:1083-90
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Monsanto Company Confidential
Existing regulatory framework is adequate for dsRNA based products
RNA-based technology has high potential for taxonomic specificity and low likelihood of adverse effects to NTOs
Bioinformatics cannot be used as standalone information for an ecological assessment
There is extremely low potential for off-target effects from saturation of RNAi machinery, immunostimulation and suppression transitivity in NTOs
Key factors that drive potential ecological risk are exposure, responsiveness, and sequence
Ecological testing for RNA-based products can be adequately assessed within the existing framework using properly designed Tier 1 assays to evaluate endpoints relevant to protection goals for NTOs
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Monsanto Company Confidential
Note: Gleit, et al. Prospective Large-Scale Field Study Generates Predictive Model Identifying Major Contributors to Colony Losses
PLOS Pathogens | DOI:10.1371/journal.ppat.1004816 April 13, 2015
• Currently EPA approved products for Varroa destructor include conventional chemicals and/or essential oils and organic acids
• Resistance has rendered 2 chemistries ineffective ~~ evidence of resistance to amitraz
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Monsanto Company Confidential
0
4
8
12
16
0 4 8 12
2014 and 2015 field trial demonstrated significant mite suppression and improvement in hive survival
2015 VARROA CONTROL TESTING– REHOVOT, ISRAEL
At week 11, Varroa mite count reduced by more than 2.1X with BioDirect treatment vs untreated
hives
WEEKS
NON-TREATED
BIODIRECT
# o
f M
ITES
/1
00
BEE
S
Su
rviv
al %
0 1 2 3 4 5 6 7 8 9 10 11 12 30 40 50 60 70 80 90
100
WEEKS M
ites
/ 1
00
bee
s
NON-TREATED
BIODIRECT
2014 VARROA CONTROL TESTING– FL, USA
At week 12, hive survival improved by more than 1.8X with BioDirect treatment vs untreated
hives
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Monsanto Company Confidential
BioDirect™ for Varroa control does not appear to influence bee survival in the absence of Varroa • Bees were treated with 1X and 10X doses of BioDirectTM and reared in boxes for three weeks • 5 boxes with 30 bees in each treatment group
Bee
su
rviv
al
DAYS
Oligo A
Oligo A
Oligo B Oligo B
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Monsanto Company Confidential
Flea beetles are highly destructive defoliators of canola causing significant economic yield loss
Attacks young plants resulting in yield loss, estimated at >$300 million damages in North America alone
FleaBeetlesaredevasta>ngpestsofCanola/Rapeseed
Stripedfleabeetle
Cabbagestembeetle
Cruciferfleabeetle
n Growers in Europe under pressure
n Potentially provides an alternative solution
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Monsanto Company Confidential
BioDirecttreatmentsshowefficacyonfleabeetlesincontrolledenvironmentassaysandinthefield
+BioDirect- BioDirect +BioDirect- BioDirect
35Daysa[er2ndspray
Field trials
Negative control BioDirect
Untreated
0
2
4
6
8
10
12
0 5 10 15
% S
urvi
vors
hip
Days Post-Infestation
100
80
60
40
20
Canola leaf disk assay
Negativecontrols
BioDirect 0.2X
BioDirect 1X
Whole plant assays
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Monsanto Company Confidential
In closing Existing Regulatory Paradigm – including at the state level - for biopesticides is appropriate for dsRNA-based products
Active research • BioDirect projects are in an early phase of
development
When developed, product concepts will inform problem formulation and regulatory testing plan
Thank you for the opportunity
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