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Sent: 19 May 2003 09:36
Subject: 55: Re: Codex food safety guidelines
[NB NB NB.....We are now entering the final week of this FAO e-mail conference on Regulation of GMOs in Developing and Transition Countries, as it is programmed to run from 28 April to 25 May. The vast majority of you who registered, have not yet sent a message to the conference. In the remaining time, we especially encourage you to share your views and experiences, seen from your country, with us on any of the issues involved in GMO regulation in developing or transition countries or to discuss points made in messages previously posted or to raise topics discussed in the Background Document to the conference. As the emphasis in the conference has, so far, been on regulation of GM crops, we also especially encourage inputs from people involved or interested in livestock, forest trees, agro-industry and fisheries to speak up and be heard..........
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This is Héctor Villaverde, Chile, in response to S. Vasanthi (Message 44, May 10).
I understand that in the current processes to implement the Cartagena Biosafety Protocol, the guidelines for the food safety evaluation of GM foods should be main global regulatory reference in relation to the establishment of a public health system on GMOs. The Protocol implies import/export regulations in essence, and under the SPS agreement (the World Trade Organization Agreement on the Application of Sanitary and Phytosanitary Measures) the systems implemented should ensure equivalency of their regulatory measures. The use of the Codex standards related to GM foods as a starting point for national regulations would be the most effective and efficient way to save time, money and human resources (and eventually challenges in WTO), specially in this case, where there is agreement between all stakeholders, including NGOs.
Food Programme Co-ordinator
Office for Latin America and the Caribbean
Las Hortensias 2371
Phone: (56-2) 335-1695
Fax: (56-2) 231-0773
Email: programalimentario (at) consint.cl
Sent: 19 May 2003 10:38
Subject: 56: Regulations must regulate, not facilitate
This is Glenn Ashton again.
An interesting contradiction emerges in recent posts.
On the one hand. the argument is made that the precautionary principle (PP) is abused by opponents to technology, in reference to groups that have taken a strong regulatory line with transgenic products. (C Kameswara Rao; Messages 52 (May 14) and 54 (May 16)).
On the other hand, Dick Richardson (Message 51, May 13) makes an elegant case around insufficient genetic information, indirectly showing the need for the PP. Given this lack of information and indeed, if Richardson's submission is read alongside Barry Commoners article, "Unraveling the DNA Myth: The Spurious Foundation of Genetic Engineering", published in the February 2002 issue of Harper's Magazine (full references and background at http://www.criticalgenetics.org/), it is clear that opposition to pressure to introduce GE foods and crops - by an emphasis on substantial equivalence and other scientifically questionable assumptions - is indeed founded upon real scientific concerns. This aspect underlines the real need for the PP.
Moreover, concerns around poor regulation of transgenics are not only scientific; there are also economic (liability and intellectual property), political (responsibility), social (ownership and gender impacts), environmental (ecology) and other concerns that must be regulated. It is therefore insufficient to regulate this technology only by scientific criteria. Far more worryingly, in light of the above references it becomes increasingly clear that the dominant paradigm of the central dogma, coupled to Cricks' sequence hypothesis, each, jointly and separately, fail to stand up in practice. That these outdated concepts form a basis for present assumptions for claims of safety and testing, whilst using a model more suited to chemical safety than genomic safety, is unacceptable.
Certainly, we need to use certain scientific criteria to regulate transgenics, but we must move away from the present emphasis on flawed theoretical frameworks that are manipulated by powerful lobby groups to suit their own narrow ends. We all know that statistical analyses can easily be abused. Given the international scope of revolving door regulation, in which the de facto lead international regulators (The United States' Environmental Protection Agency (EPA) and Food and Drug Administration (FDA) among others) are especially compromised by their close associations with industry and the implications of negative influences on meaningful regulation are highlighted.
Regulations must regulate, not facilitate. In most cases internationally (nations like Switzerland, Austria etc with highly developed agricultural inspection and research regimes are exceptions and have as a result taken a conservative view of the desirability of transgenic crops), regulations have become a one way street that facilitates introduction of transgenic crops with little counterbalance. Democratic regulatory interaction is undermined.
Also, the cost of rigorous regulation is clearly onerous, especially on developing nations and a principle of 'user pays' must be established. The user must be the party responsible for introducing the product into the market. However, it is difficult to divorce 'user pays' from buying or compromising objectivity in oversight practice. The cost of regulating transgenic crops bears closer examination. Segregation costs are passed on to consumers against a marked reluctance to introduce even a functional or meaningful international labelling regulatory framework. While consumers contribute directly to the cost of regulation and biosafety monitoring inspections, it appears that tails they loose, heads they pay.
Regulation of anything, be it guns, chemicals or transgenic organisms, must be meaningful and democratically consultative and accountable. The present international regulation of transgenic crops is neither.
The ironic tragedy is that the real potential of agricultural biotechnology is being marginalised by those who 'promote' it. Contrary to assertions made in this debate (C Kameswara Rao, Message 54, May 16) and elsewhere, most of those questioning the rationale and methodology governing existing GE crops are not opposed to biotechnology or technological innovation per se. On the contrary.
ekogaia (at) iafrica.com
Sent: 19 May 2003 13:51
Subject: 57: Sundry comments
I am E.M. Muralidharan from India and I am involved in research into some aspects of the biotechnology of forest trees and medicinal plants.
The arguments for relaxing the regulations for well known and tested GM events is perfectly justified from a corporate point of view and, indeed, where a technology proven to be safe and useful is concerned. But that is perhaps stating the obvious. If a situation like the one Prof Rao (Message 37, May 9) writes about (where a GM event is repeated in the same crop but is forced into prolonged trials every time it is introduced by a different company or into a different country) then it is not a reasonable assessment of the risks involved. But again, is the concern actually about such familiar situations or is it more about the risks of an inadequately investigated event that might manage to pass through, if a less stringent regulatory regime was to be adopted?
The need for abundant precaution in regulations is clear in some of the postings, particularly the one by Budi Prakoso (Message 50, May 13), which points to the limitations that developing countries face technically. Effective implementation in the face of vested interests and unscrupulous elements has been shown to be difficult in several instances, including the case of Bt cotton that came into the hands of farmers, illegally, in India. I am also glad that the `classroom lecture' from Dick Richardson was posted (Message 51, May 13) which puts several things in perspective as far as the risks are concerned, for the non-technical reader. I hate to think of transgenic forest trees being deployed when not much of their genetics and phenology is known. [Phenology is the study of periodic biological phenomena, such as flowering in plants...Moderator].
It appears to me that most advocates of GMOs argue for the unique benefits that would come about through their rapid deployment (with minimum of regulatory hassles), by pointing to the dangers of continuing with more conventional technologies, namely use of chemical pesticides and fertilizers, the lack of essential nutrients in staple food, crops succumbing to natural stresses and so on. As I pointed out in the previous conference of the FAO Biotechnology Forum, entitled "What should be the role and focus of biotechnology in the agricultural research agendas of developing countries?", this anxiety is a bit misplaced if we are ready to consider alternative technologies which are rather conventional but simple, cheap and safe. These have unfortunately been eclipsed by the hard sell with which modern techniques like GM are promoted. We can therefore afford to wait a bit longer for GMOs to be field-tested to the satisfaction of all. [See Dr. Muralidharan's Message 55 in the previous conference...Moderator].
E. M. Muralidharan
Kerala Forest Research Institute
Peechi - 680653,
emmurali (at) kfri.org
Sent: 19 May 2003 17:11
Subject: 58: Regulations must regulate and facilitate
This is Professor J Ralph Blanchfield, a professional food scientist with no links with the biotechnology industry, and neither root-and-branch for GM nor root-and-branch against GM. A scientist should not be root-and-branch anything except for the methodology of science.
Dick Richardson's message (nr. 51, May 13) boiled down in essence to eight words -- "We don't know enough so don't do it". Despite his lengthy dissertation, his arguments apply with even more force to the relatively blind insertion of multiple genes in traditional breeding methods. "We don't know enough" is a euphemism for "Never". Of course, we can never know all there is to know about any subject. Thankfully our ancestors did not adopt that reason for rejecting progress; if they had we would still be in the Stone Age. In more recent times, there would be no electricity; the first passenger flight would not have taken place, so there would be no air travel; the first surgical operation would never have been carried out so there would be no surgery; the first anaesthesia would never have been used, so there would be no anaesthetics -- the list could be endlessly extended. Exactly the same arguments were used early in the 20th century to try to prevent the legalization of milk pasteurization. We can be thankful that it was eventually legalized and over several decades has saved untold numbers of lives that would otherwise have continued to be lost to milk-borne tuberculosis - second only to clean water as the most important public health measure ever adopted.
Properly used, the precautionary principle is not a device to block progress. It and risk assessment are not opposites but two sides of the same coin. Regulation should regulate but, contrary to Glenn Ashton (Message 56, May 19), it should also facilitate.
Prof J Ralph Blanchfield, MBE
Food Science, Food Technology and Food Law Consultant
Chair, External Affairs, Institute of Food Science and Technology
Webmaster / Web Editor, Institute of Food Science and Technology
Vice President, European Food Law Association of the UK
Immediate Past Chair, IFT Committee for Global Interests
Adjunct Professor, Michigan State University
IFST Web address www.ifst.org
Personal Web address www.jralphb.co.uk
jralphb (at) easynet.co.uk