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-----Original Message-----
From: Biotech-Mod1
Sent: 30 May 2003 13:14
To: 'biotech-room1@mailserv.fao.org'
Subject: 84: Prioritizing the regulation of for-profit GMOs

This is Dr. Justin Mog from the University of Wisconsin-Madison, again.

Prof. Blanchfield's asserts (Message 78, May 26) that: "I think the future pattern of research and development will be much more by government agencies, charitable foundations and international research institutes and far less by the biotech companies." What is the basis for such an assertion, particularly in the context of the poorer nations that are the focus of this conference? Have government agencies, charitable foundations and international research institutes historically lead the way in the research and development (R&D) of many other such technologies introduced to 'Third World' communities? Isn't potential profitability a central driver of R&D investments for expensive, high-tech advances like GMOs? As I see it, experience to date and the fundamental nature of existing economic incentives suggest that, contrary to Prof. Blanchfield's assertion, it is for-profit biotech companies which are most likely to be leading the way in GMO R&D; while governments and others struggle to respond appropriately to the technologies introduced by these firms. I believe that this point is critically relevant to this conference's thematic question of how resource-strapped governments ought to prioritize GMO regulation.

In an earlier Message (nr. 16, May 5), I laid out an argument for prioritizing the regulation of for-profit GMOs vs. those not developed for profit, saying that: "for the purposes of protecting the interests of the most vulnerable members of their agricultural populations, regulators in poorer nations might do well to restrict the access granted for-profit GMOs to domestic agricultural input markets." Subsequent messages have tended to focus the debate about how to regulate on technical aspects of the technology itself, rather than the motivations behind its development and distribution. I won't restate my argument here, but I remain eager to know whether other participants agree that the for-profit vs. not-for-profit distinction is a useful one for prioritizing GMO regulation in the poorer, more vulnerable nations of the world.

Finally, I will just note that, perhaps, we may be blind to the importance of for-profit biotech firms because most of the participants of this conference seem to come from the not-for-profit side (myself included).

Justin Mog, PhD
Gaylord Nelson Institute for Environmental Studies
University of Wisconsin-Madison
315 N. Ingersoll St.
Madison, WI 53703-1611
U.S.A.
E-mail: jmmog (at) wisc.edu

-----Original Message-----
From: Biotech-Mod1
Sent: 30 May 2003 14:56
To: 'biotech-room1@mailserv.fao.org'
Subject: 85: Re: Prioritizing the regulation of for-profit GMOs

This is Prof J Ralph Blanchfield responding to Dr Justin Mog's (Message 84, may 30) request.

In referring to the future pattern I thought my context made clear that I was thinking not of more applications of current "first generation" GM (which were developed by the biotech companies primarily for their principal customers, the US farmers) but of the second and subsequent generations of GM, of the kind precisely for "the poorer nations that are the focus of this conference". The forerunner of these was Dr Ingo Potrykus's golden rice project, funded by the EU and the Rockefeller Foundation and now being further developed, with indigenous rice varieties, at the International Rice Research Institute and 13 other rice institutions across Asia. Yes, it has made use of a number of patents owned by biotech companies, but, as stated in my sentence immediately preceding the one quoted by Dr Mog, the patent owners have donated royalty-free licences for this purpose. The future is, of course, a matter of opinion, and in scientific matters rarely foreseeable merely by extrapolating from the past and present, but in my opinion this will be the main sort of pattern by which future GM crops will be developed that will provide such additional advantages as:
1. Ability to grow in inhospitable environments (conditions of drought, saline soils, aluminium-rich soils, extremes of temperature)
2. Improved nutrition attributes (especially of micronutrients) and addressing the major nutritional deficiency diseases that afflict such a large number of our fellow human beings, predominantly in the poorer countries - (Vitamin A deficiency disorders (VADD); nutritional anaemias (especially iron); and iodine deficiency disorders (IDD), the latter a desirable target for which no GM research strategy has yet been developed as far as I am aware).

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
IFST Web address www.ifst.org
Personal Web address www.jralphb.co.uk

[This discussion thread on the future pattern of GM research and development is now cut. Only messages directly dealing with the theme of "Regulating GMOs in developing and transition countries" will be posted...Moderator].

-----Original Message-----
From: Biotech-Mod1
Sent: 30 May 2003 16:32
To: 'biotech-room1@mailserv.fao.org'
Subject: 86: The objective and content of GMO regulatory frameworks

This is Gert Willemse from South Africa again.

Having made use of examples to make my point in the past, the discussions equating GMOs to planes and boats and trains (and motor cars) have convinced me not to use these examples any more. It really is a circular argument with some truth in any point of view held, not resolving anything.

What did become clear is that much disagreement exists as to the "what" (objective) and "how" (content) of regulatory frameworks for GMOs. I cannot agree with Justin Mog's view (Messages 16 and 84) that regulatory distinction should be made between for-profit and not-for-profit GMOs. If the point of departure in regulation of GMOs is a risk-based one (which it should be) such a distinction would automatically assume that the risk lies not with either the technology nor the product, but rather with the objective or purpose.

What the circular arguments do highlight is that serious consideration needs to be given to the content and institutional framework of regulatory systems during the design phase. When considering the arguments about plants produced through normal breeding and those that were genetically engineered, and the different approaches with regard to regulation, it becomes clear that the same regulatory criteria are not being applied for GMOs and for their non-GMO equivalents. And yet, the impacts through the "non-regulated" introduction of agricultural crops worldwide are enormous. The total global cost of common agricultural pests (introduced as aliens together with crop plants) would be enough to cover the development funding of several poor nations. The same holds true for invasive alien species of every taxonomic class imaginable, imported for purposes ranging from horticulture to the pet trade, resulting in huge losses due to, among others, diseases and decreased environmental services. The disaster that befell the European crayfish populations more than adequately illustrates this point. [The reference here is to an example of an introduced disease which severely impacted biodiversity - the crayfish plague (Aphanomyces astaci) which decimated European crayfish populations, see e.g. http://www.fao.org/DOCREP/003/AB412E/ab412e09.htm ...Moderator].

It is for this reason that I find the biosecurity concept such an attractive one, to deal with all risks on an even keel. [This concept was discussed in Section 4.d of the Background Document...Moderator]. If we continue to apply different criteria in risk assessment and risk management based on our perceptions and individual likes and dislikes, we will continue to generate disasters, while stifling development that is needed above all by developing countries.

Finally, in response to Nazimi Acikgoz's message (No. 83 of 29 May), the principle of not allowing a GMO into the species center of origin is one that should never be compromised. If an argument of costs is brought into the discussion to facilitate any decision where the principle is considered to be waived, such an argument should be based on full cost-benefit analysis taking into account potential costs to, and benefits of, the base genetic resources as well as the potential impacts on ecosystem goods and services, and heritage values. I believe in such an instance the cost-benefit equation would not be in favour of the GMO.

Dr Gert Willemse
Private Bag X447
Pretoria 0001
South Africa
Tel: +27 12 3103836
Fax: +27 12 3207026
bioconsult2002 (at) yahoo.co.uk