Genetically Modified Organisms: hearings

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The aim of this report is to summarise the main events at the meeting and identify the key role players. This report is not a verbatim transcript of proceedings.

ENVIRONMENTAL AFFAIRS AND TOURISM PORTFOLIO COMMITTEE
30 October 2001
GENETICALLY MODIFIED ORGANISMS: HEARINGS

Chairperson: Ms G. Mahlangu

Documents handed out:
GMOs: Legislation & Cartagena Protocol on Biosafety (Dept of Enviro Affairs & Tourism)
GMO Act, 1997: Presentation (Department of Agriculture)
Genetically Modified Food: the Impending Disaster (Southern African Catholic Bishops Conference) (Appendix 1)
South African Catholic Bishops Conference submission ( (Appendix 2)
South African Freeze Alliance on Genetic Engineering submission (Appendix 3)
Green Party of South Africa submission (Appendix 4)

SUMMARY
Presentations were made by various government departments, non-governmental organisations, and others on the topic of genetically modified organisms (GMOs), their impact on South Africa, and what should be done in terms of regulation, use and public awareness. The presentations represented many different views both in favour of and against genetically altered foods and products. The Chairperson then opened the floor to questions and discussion. Following discussion, the Chairperson thanked all present for assisting the Committee in learning more about GMOs.

MINUTES
The Chairperson welcomed the Committee members and all others present. Presentations would be made by several government departments and other non-governmental groups, and that would be followed by an opportunity for questions and discussion. She then gave the floor to the first presenter from the Department of Environmental Affairs and Tourism (DEAT).

Legislation and the Cartagena Protocol on Biosafety
Mr G. Willemse, Deputy-Director of Biodiversity Management for DEAT, was the first to present discussing GMOs with regard to the Cartagena Protocol on Biosafety. The Cartagena Protocol on Biosafety was the protocol to the Convention on Biological Diversity. It was adopted in June 2000. To date, there were only seven ratifications, and Norway was the only country to ratify it that actually dealt in GMOs. All other countries are still in the process of assessing the impact. The Protocol would enter into force ninety days after the fiftieth ratification. Mr Willemse told the Committee that the objectives of the Protocol were to ensure an adequate level of protection in safe transfer, safe handling and safe use. This applied only to living modified organisms (LMOs) resulting from modern biotechnology in consideration of human health. Mr Willemse explained that one obligation of the Protocol was advanced informed agreement (AIA) that entailed notification from export party to import party requiring a minimum amount of information including risk assessment. The import party would have to acknowledge the notification within 90 days and make a decision within 270 days. Other obligations concerned information sharing, handling and transport, packaging and labeling, and public awareness and participation. Obligations on the countries party to the Protocol included enacting the Protocol in that country, having a national focal point, installing competent national authorities, and having a biosafety clearing house.

Mr Willemse then discussed the chapter on biosafety in the Draft Biodiversity Bill that provided for regulations under the Act by implementing the Protocol and fulfilling the requisite national obligations. Consultation with the proper departments and authorities was concluded in January 2001. Because there was much concern from stakeholders that South Africa would not be able to implement it, the process would call for several steps before implementation that was aimed for January 2003. The capacity building plan and implementation strategy would be concluded by June 2002, and that would leave ample time to implement by the set date.

Genetically Modified Organisms Act, 1997
Dr S. Moephuli from the Department of Agriculture presented next, and he spoke about the Genetically Modified Organisms Act, 1997. He said that there were various international agreements and national efforts aimed at controlling GMOs. The aims of the GMO Act, he explained, were to provide for responsible development, production, use and application of GMOs in a manner that would limit possible harmful consequences to the environment. The bio-safety structures called for in the Act included an executive council, registrar, advisory committee, inspectors, appeals and regulations. He listed the representatives from the various departments on the executive council and their duties and powers. The executive council could approve the release of GMOs, and the representatives would advise the Minister on the issue. The advisory committee would act as a national advisory body on GMOs. The advisory committee would consist as well of non-government members and technical experts.

Dr Moephuli continued by listing the three issue categories that were the main concerns of GMO use: farmers, human health and environment. Farming concerns were access with regard to GMOs and seeds, sustainability of costs and crops with the use of GMOs, and benefit sharing if, for example, a community had developed a particular seed of which a company makes a sequence. Human health concerns included issues such as antibiotic markers when an antibiotic gene was used alongside another gene to see whether or not that gene had already been inserted. This could lead to the problem of multi-drug resistance, so applications involving this practice were no longer approved. Other human health concerns were allergenicity. In terms of the environment, consideration of applications included consideration of the probability that a GM plant might become a weed. Also, the potential effect on biodiversity would be considered as well. The approach taken for consideration was based on scientific assessments and on a case by case basis that would allow for research and provide for inspections. Risk management included conditional permits and requisite monitoring and evaluation.

In administering the Act, Dr Moephuli stated, they would be involved in risk assessment on applications, and they would allow for public input and the input of independent experts and other departments as well as consideration of socio-economic factors and national needs. Decisions would be made with all of these considerations. He said that South Africa had an increasing demand for more food, so this required a higher yield per unit of land, water, energy and time. In conclusion, he claimed that the National Biotechnology Strategy could provide the appropriate method for determining how to best utilise modern biotechnology to increase agricultural productivity without causing adverse effects on biodiversity, human health and economic stability.

Department of Health Presentation on GMOs
Ms W. Van Rijssen, Deputy Director of Food Control for the Department of Health was next to present. She first defined biotechnology saying that it had been around as a practice for a long time before modern biotechnology as we know it. Gene technology today consisted of taking genes from any biological source and implanting them in something else. This had been used for awhile in special strains of yeast and in cheese-making procedures. Additionally, some common vaccines were also the product of GMOs. The Food and Agriculture Organization (FAO) of the UN had no problems with GMOs as long as they did not have a negative effect on the environment or human health.

She then brought up the Codex Alimentarius of the FAO. The Codex Alimentarius was a food code meant to be a global reference point for international standards in food control, and it was created to protect consumers and ensure fair trade. A Task Force on Food Derived from Modern Biotechnology had been created in part to set out guidelines for the conduct of safety measures with regards to these products. Ms Van Rijssen stated that a common question for Codex concerned what overarching scientific principle would need to be applied to safety and nutritional assessment. She said that this was answered in a more complete form on their web page, but, in brief, they should have sufficient safety assurance on long-term effects. Both gene food and traditional food needed long-term monitoring, but this incurred long-term costs as well. Gene food was subject to the same safety requirements as conventional food. She then discussed GMO risk analysis in the form of risk assessment, management and communication. She argued that the European Union Biodiversity Report found no new or extraordinary risks of GMOs outside of normal uncertainty, and GMOs were likely safer than conventional plants and foods, in her opinion. A number of expert groups had been consulted.

Ms Van Rijssen then discussed labeling with regard to GMOs. Different countries appeared to be doing their own thing, and this was a challenge to overcome. She believed that South Africa was particularly progressive with its labeling procedure. Consumers had the right to know what they were eating and to make informed choices. According to Codex Alimentarius principles, no food should be presented or described in a false or misleading manner. Any claims that could not be substantiated, gave doubt to safety or instilled fear in consumers would be prohibited. She then explained various methods of validating claims stating the disadvantages and advantages of each method.

Proceeding to draft labeling regulations, she described the proposed mandatory labeling for changes in nutrition or toxins, allergens, and genes. This labeling was voluntary in cases of improved or enhanced characteristics or for non-genetically modified foods. The gray area considered foods that might contain GMOs, and this would not require labeling. Labeling a food ''non-GM'' allowed for a tolerance of 1% GM material, but labeling a food ''GM free" allowed for zero tolerance. All claims would have to be validated and certified by an accredited body. The South Africa National Accreditation System allowed for quality control and consistency of these accredited bodies. The Identity Preservation System was created to segregate non-GM foods from GM foods, also as certified by accredited bodies. Concerning implementation of labeling, Ms Van Rijssen admitted that law enforcement was difficult, food costs would likely increase 8 to 28%, the impact on the informal food sector would be negative, and low efficacy would result from low literacy levels and too little information. She said, however, that they must have consumer confidence in knowing whether or not what they ate contained GM substances. She also emphasised that non-GM foods were not necessarily safer than GM foods, and only safe foods would be released for sale, but she concluded by saying that risk assessment and increased information on GMOs was crucial.

GMO Public Awareness Campaign
Mr D. Tshabalala, Campaign Manager of Communication for the Department of Agriculture, spoke next. He said that everyone at the meeting was there to engage as partners, and some were in favor of GMOs while others were not. He thanked the Chairperson and the Committee for the opportunity to present, and said that everyone there was a prime target for public awareness. He appealed to them all to become soldiers in the GMO Awareness Campaign. The World Food Summit, 1996, was the basis of the work of the Department on this issue, and it required consideration of economic impact, opening trade, and environmental assessment, to begin with. He said that the end result was supposed to be a ''full tummy'', but a ''full tummy'' would have to be informed. Labeling was not an effort to warn but to inform.

Mr Tshabalala stated that the various departments had already joined in collaboration, and GMOs were already being used in South Africa, so the duty now was to inform people of the impact. The steps they had already taken included t-shirts, brochures and posters, as he explained was the initial necessary step for any government campaign, but he said they would be coming to various interested groups and stakeholders next to seek advice on what they needed to do. They needed to work together to come up with slogans as a team, and they had to first inform Parliament so that Members would be ready to face the media that was already claiming GMOs to be bad. He referred to the Canadian farmer from the previous Committee meeting who was "soliciting the whole world" but said that the farmer's concerns were not the same issues they were dealing with. For the public awareness campaign, the Department would issue a media statement and get the Minister interviewed, but this was not enough since there were many areas without even radio access, so other methods would have to be used. He said that they would have to go out to rural areas to show that GM foods were cooked the same way and the results were the same. He said that this was how they were beginning, but they would need cooperation from everyone.

GM Crops: Part of the Solution for Soil
Prof J. Thompson from UCT presented next and discussed the benefits of GM crops for soil in South Africa. She explained that Africa was an old continent, and many nutrients had been lost from the soil, and a chronic shortage of water in sub-Saharan Africa was not helping this situation. Though GMOs were not a total answer, they could be an important part of the solution. She stated that South Africa needed to grow more organic material on its limited arable land because simply producing a higher yield was not the answer. It was necessary that the soil have more nutrients after a crop was grown than it currently did. GMOs had become popular because they decreased the need for insecticides since they produced insect resistant crops, and this was a great help to many farmers who could not afford insecticide. Many diseases transmitted through insects were major detriments to farming that often decimated crops. She explained that Europe did not have food shortages and distrusted its regulatory systems, but that should not mean that Africa should not utilise these technologies. She then thanked the Chairperson and Committee for the opportunity to present.

Biowatch Presentation on GMOs and the Environment
Ms E. Pschen-Strauss of Biowatch South Africa was the next presenter, and she began by stating that the debate at hand was one that many were trying to simplify. She commented that the debate could not stay only within the scientific community because it was not qualified to comment on the social, trade and environmental impacts of GMOs. Non-governmental organisations would have to be included. She stated that there was much concern that GMOs in South Africa would compromise their environmental integrity, and there was not yet enough debate or analysis of risks and benefits. Up to now, it had been assumed to be something South Africa had no choice about, but many countries had already chosen not to accept GMOs. She questioned the rationale of Africa's fear of being left behind on this issue. Once this option was chosen, they would not be able to turn back. She added that claims of higher agricultural yields had not been proven.

Ms Pschen-Strauss continued by discussing matters in legislation on this topic that needed attention. The GMO Act, according to Biowatch, had many problems, and there had been inadequate participation in developing it. She said that placing an advert in the newspaper was not sufficient, and information and monitoring of the subject continued to be insufficient. She also commented that the process of developing the Act had lacked transparency and questioned whether only scientific assessments had been considered. Biowatch supported a rewrite of the Act. On the National Biotechnology Strategy, the period for public comment had closed. Though the Strategy referred extensively to perceived benefits that might come along, Ms Pschen-Strauss stated that none of these benefits had been seen, and the legal framework for regulating was inadequate. She proclaimed that Biowatch urged the development of a policy in which everyone could participate freely, and they would love to take part.

Ms Pschen-Strauss told the Committee that she had looked over some of the Public Awareness Campaign, but it said nothing about procedure. She also commented that information would only be beneficial to those who had the luxury to choose, but the poor could not afford this luxury. Additionally, she believed independent monitoring needed to be done on farmers and farming in South Africa, and she questioned why permits were being granted despite the high levels of uncertainty. In conclusion, she wanted to know why South Africa was accepting a technology that so many other countries were rejecting.

The Chairperson said that it would be sad if the Committee was left with no time for discussion, so she asked the remaining presenters to refrain from repeating information or using extra time for over-emphasis.

Call for a Minimum Five Year Moratorium on Genetically Engineered Foods and Products
Ms K. Kallmann of the South African Freeze Alliance on Genetic Engineering presented next, and she explained that her organisation urged a minimum five year moratorium on genetically engineered foods and products. The consideration of GMOs concerned several departments as it cut across various issues including food security, biodiversity integrity, trade and socio-economic factors, to name a few. The Alliance focused on several of these issues, and she offered several suggestions that the Alliance believed would make a good starting point from which to look at the complex issue. Firstly, they suggested the development of a national policy on genetic engineering to address issues concerning genetic engineering in food, agriculture and forestry. This would need to include a comprehensive cost-benefit analysis comparing genetic engineering to other procedures used in South Africa and an assessment of the impact on sustainable agriculture, food security, ecosystems and biodiversity, public participation and consumer choice, animal health and welfare, and ethical and religious sensitivities. Secondly, the Alliance urged the Committee to sign and ratify the Biosafety Protocol as soon as possible. This would require a drastic amendment and alteration of the GMO Act of 1997, but the Act had been written initially with the knowledge that it would need to be revisited. Despite the standing review, no revisiting had occurred, and the technology was proceeding unchecked without full knowledge of the dangers.

The third suggestion concerned the Environmental Impact Assessment Regulations currently under review by DEAT. Ms Kallmann stated that the Committee needed to ensure that provisions related to GMOs would receive immediate consideration and review. Fourthly, urgent policy decisions had to be made regarding the institution of measures for safety testing of GMOs and GMO products. The final suggestion was that the Department of Health needed to finalise draft regulations requiring labeling of genetically engineered foods so that consumers would be properly informed. Ms Kallman argued that five years was the minimum time-period necessary for accomplishing these tasks, so a moratorium would need to be placed on import and export of genetically engineered foods and crops and on patents of genetic resources for these purposes. If these guidelines were not followed, South Africa could suffer long-term for the short-term benefits of companies profiting on this exploitation.

Regional Representation for South Africa on the GMO Issue
Ms Doreen Mnyulwa, Executive Director of the Biotechnology Trust of Zimbabwe, addressed the Committee next. She stated that Zimbabwe was a signatory to the Biotechnology Protocol, and they believed that South Africa should be as well. They believed that something was wrong with what South Africa was doing since the international scientific community agreed with the Protocol. In Zimbabwe, she explained, biotechnology was seen as a regional issue because insufficient regulation and rules could provide opportunities for GMOs to slip across borders unwanted. South Africa should join them to work together as a region. She also commented that South Africa was usually represented by non-governmental organisations on these issues when the government should be participating. She also wanted to encourage the Department to have an objective and fair Public Awareness Campaign. With this technology, there had to be risks or there would be no need for precautions and protocols. She then thanked the Chairperson and the Committee.

Submission on GMOs from the South African Catholic Bishops' Conference
Sr A. Laub represented the Southern African Catholic Bishops' Conference (SACBC) in her presentation regarding concern over the speed at which GM technology was being introduced in South Africa. She told the Committee that she was coordinating a program in South Africa called Ecohope. They worked with emerging farming communities where people got land but could not farm economically because of costs such as farming equipment. The concerns of SACBC and those on the ground were that, without prior information, many people quickly latched on to genetically modified crops, but, if their crops were wiped out, the seed would no longer be available. Farmers were afraid that their knowledge and seeds would be taken away from them. Sr Laub told the Committee that the American Food and Drug Association claimed to have found equivalents between GM and conventional crops, but this claim was impossible because they did not know enough about GM products and they had not had enough time to judge their safety.

She stated that the hope of GM crops reducing the need for insecticides had failed as well, and some way to successfully reduce this need was necessary for the safety of crops and animals. She also commented on the difficulty of controlling GM crops and their bio-relatives used for genetically melding crops because of cross-pollination. It had become difficult to access money for organic farming, but they needed food they could make from their own traditional resources that they could control. Sr Laub then discussed seed security. Farmers in the USA wanted to go back to conventional farming but could not because of seed contamination. South African farmers used the same seeds for hundreds of years, she argued, and having to buy expensive seeds every year for GM crops would ruin their self-reliance. Already, the use of GM seeds in the Northern Province had not been very successful because farmers found it hard to control. Concerning labeling, she believed that poor people would eat whatever they could obtain, so this would make little difference in their ability to choose. Sr Laub stated that taxpayer money should rather be used to support self-reliant farming rather than GM crops. In conclusion, she read a statement against GM farming signed by 24 delegates from 18 African countries to the UN Food and Agriculture Organisation.

Monsanto Presentation on the Benefits of GM Crops
Mr W. Green, the Biotechnology Regulator Manager for Montsanto, Sub-Saharan Africa, introduced Mr C. Mailou of Monsanto who told the Committee that they had brought a farmer to attest to the real benefits of GM crops. Mr M. Nxumalo, a South African farmer, then spoke to the Committee in Zulu, and his statements were translated by Mr Tshabalala. He told the Committee that he farmed in an area where they grew cotton, maize and vegetables. In 1999, they started planting a GM crop from Monsanto. It cut the costs and time on labour and increased their income. Their concern had been with the dangers of pesticides they normally used, but now they could avoid that risk. Formerly, they used pesticides against worms, but now they only had to spray for the particular kind of worms resistant to the crop. This worm, however, could be killed with a cheap and relatively safe pesticide. He said that the arrival of this GM crop was like the arrival of Freedom Day for his community. They were quite happy to use the product and would not be happy to return to using maize. He thanked everyone present for the opportunity to speak.

Green Party Presentation on the Dangers of GMO Technology
Mr G. Ashton of the Green Party of South Africa was the next to speak. He first asked why the government so easily questioned beliefs and studies on HIV/AIDS but had no problem accepting GMOs without question. Mr Ashton stated that he was internationally regarded as an expert on GMOs and intellectual property, and he linked the issues of patents and corporate control, as well as commercial interest, to both the issues of HIV/AIDS and GMOs. He wished that the government would not automatically accept that GMO technology was necessary for feeding and uplifting South Africans because many alternatives were available despite the arguments of corporations hoping to profit. Biotechnology could bring great benefits but could also bring great problems, and he believed that research and consideration of the potential impacts of GMOs within a couple of decades had not been sufficient. Mr Ashton told the Committee that the sale of two of the country's largest seed interests to Monsanto, and the expiration of their patent on glyphosate weedkiller, should be a warning. This technology was largely connected to the rise of herbicide resistant weeds worldwide, but it had been refused throughout much of the world and was, therefore, being dumped in Africa.

Mr Ashton said that concern also centered on the lack of oversight of GM crops in the country, and the issue of insufficient transparency and poor control had already been brought before the Committee to no avail, and the Green Party was uncertain of whether the state even had the capacity to control GMOs properly. They wanted to know if sufficient research had gone into the effects on the biodiversity as well. No indication had been made that the State had a proper understanding of how serious this issue was. He believed that only the corporate stakeholders truly understood the importance of South Africa's genetic capital, and he disapproved of the bias toward "corporatisation of our natural heritage" that should be more concerning to the public than the privatisation of State corporations. He told the Committee that the Green Party supported advances in biotechnology but only with appropriate precautions and under government rather than corporate control. If it was a matter of feeding the nation, there were many alternatives that the Green Party would gladly share. They called for a commission of enquiry into the ramifications of the exploitation of, and the dangers to, natural capital. He then thanked the Committee.

The Chairperson thanked all who had presented for assisting in a better understanding. She said that they had heard both sides and had discussed this many times. She then opened the floor for questions and discussion.

Questions and Discussion
Mr R. September (ANC) asked Mr Green how widespread Monsanto had found acceptance of their seeds in South Africa and how much had they consulted with the government.

A female farmer told the Committee that she wanted to talk to them about the seed. She said that people in rural areas saw the GM process and seed as a breakthrough. They knew that it would resist many problems and produce a yield. Since women were involved in the weeding, and they used chemicals to kill weeds, they saw GM seeds as reducing the burden on women. This helped to restore the dignity of rural people and to restore agriculture. They now got a higher yield to feed their animals and themselves, and she wanted to thank the Department of Agriculture for the opportunity.

Ms J. Chalmers (ANC) then brought up the Executive Council on GMOs created by the GMO Act. She said that this gave no chance for public participation, and Section 18 revealed restricted information availability on GMOs. She also believed that Section 17.2 was inappropriate because it placed liability on those who consumed GM products rather than those producing.

Another member of the Committee asked how many inspectors were involved in monitoring GMOs, and she asked why South Africa had not yet signed the Protocol.

Ms J. Semple (DP) mentioned Ms Van Rijssen's comment that only a small affluent sector was putting pressure on the Department of Health for answers. She wondered if this was only because they were the informed ones so GMOs could, therefore, be dumped on others. Concerning the matter of having choices, Ms Semple also commented that farmers should have choices as well about what to plant. She said, however, it all came down to the fact that, like every advancement of this sort, it had not been around long enough for questions to be answered.

A representative from a non-profit organisation based in Khayelitcha spoke next and Mr Tshabalala translated the comment. He said that there had been success stories, but many farmers getting involved now were committing suicide with the choice to use GM crops. He argued that they needed to be careful not to fall victim to big companies, and perhaps they simply needed more time before they would know.

The Chairperson stated that this was a meeting of Parliament, and many others had had a chance to speak, so they needed to give Parliamentarians a chance to ask questions and comment now as well.

Ms Pschen-Strauss from Biowatch commented on the improved yields spoken of by the farmers. She argued that, if a new variety had been planted without gene alteration, it might have also produced a larger yield, so they could not be certain it was only the GM factor that caused the success.

Mr Nxumalo replied that, at first, only a small portion of the GM seed was used, but they then realised that they were losing on the traditional crops, so they changed their focus to the GM crops.

Mr Green, in response to Mr September's questions, said that it was difficult for a company to communicate with the population at large. They had communicated with the government about the implications, and the government had pamphlets that answered many everyday questions. He agreed that it was necessary to get information out to the people. Concerning Monsanto's growth in the country, he said that they had begun with relatively small groups until about two or three years ago, but it was much larger now, involving about 300 people. They had merged with other companies as well. They currently had 40% of the market in seeds.

Mr Tshabalala then responded to other queries he believed had come up. He asked why South Africa had to wait for the first world before capitalising on GM technology. He said that they had all represented their views based on the principles they stood for, but they needed to work together as a country to assure that GMOs were used in a positive way.

Mr Moephuli of the Department of Agriculture then said that their duty was not to supervise agriculture but to ensure that they had an environment sustainable for agriculture. Concerning public participation in the GMO Act, he said that members of the public were invited before finalisation to put their concerns in the newspaper, and these were collected and reviewed. They also had experts from the public sector involved. About confidentiality, GMO permits could be accessed, and they kept copies of the permits, but some aspects of the information they were obliged to keep confidential. The Department could look into revising the aspects on liability, but the definition of 'user' was very particular, so this was not as inappropriate as the Committee member might have thought. He also spoke on inspections saying that there were only certain points of entry where agricultural products could be imported or exported. The Department currently had 20 inspectors, but there would be efforts to increase the number.

The Chairperson asked that someone respond to the declaration that South Africa was often represented only by non-governmental organisations in regional discussions and meetings.

Mr Moephuli said that DEAT was the Department in charge of GMOs on the international level.

Mr Willemse of DEAT argued that it all involved "political passage of the buck." He then commented on South Africa's failure to sign the Protocol. He blamed this on technical issues and poor timing of restructuring within the Department. The time during which they could have signed had already passed, but they could still choose to adhere to the Protocol, which was the same as signing and ratifying it.

Ms Mnyulwa of Zimbabwe argued that South Africa lost out by not signing, and she stated that getting involved in regional efforts would also be important.

Dr R. Rabinowitz, a Member of Parliament (IFP), apologised for having not come earlier, but she wanted to make the point that coordination of the Departments involved was vital to improving the situation.

The Chairperson thanked everyone present for helping the Committee to become better informed. The meeting was adjourned.

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Appendix 1

Southern African Catholic Bishops' Conference
PARLIAMENTARY LIAISON OFFICE

Genetically Modified Food
The Impending Disaster

OCCASIONAL PAPER 7
September 2001

GENETICALLY MODIFIED FOOD
The Impending Disaster

Introduction
Many thousands of hectares in South Africa have been planted with genetically modified (GM) crops. And because we have no proper labelling of foodstuffs, we do not know how much of the food we eat everyday has been contaminated by genetic manipulation.

Nor do we have any comprehensive understanding at this stage of the consequences of eating genetically engineered (GE) food. There have been reports suggesting terrifying and irreversible consequences for human beings and for the environment, but even more horrifying is the fact that big companies have been allowed to put these foods on the market long before adequate scientific monitoring of the long-term consequences has been carried out.

This paper attempts to cover some of the main issues and controversies relating to the genetic modification of food, highlighting real and potential dangers, looking at the economic and financial interests at stake, and providing an overview of the legislative position adopted here and abroad.

The Need for a Freeze FIVE YEAR FREEZE
In November 2000, the Southern African Catholic Bishops' Conference (SACBC) issued a press statement supporting the campaign calling for a five-year freeze on genetic engineering and patenting in crop and food production. The Bishops' stand is mainly based on the precautionary principle. So far, no rigorous long term testing has been carried out to ascertain the effects of genetically engineered crops and foods on humans, animals, plant-life and soil. Doubts about the safety of the new bio-technologies have been confirmed by the results of scientific studies and many scientists are warning that genetically modified organisms (GMOs) pose risks to health, for example, increasing the incidence of allergies, toxic reactions and antibiotic resistance.

In 1999 the British Medical Association called for an open-ended moratorium until there is greater scientific certainty about the safety of GM seeds and derived products. In February 2001 the Royal Society of Canada added its voice to the call for a moratorium. Many scientists around the world have joined the call, along with farming organisations, especially in the USA, which are advising farmers to discontinue GE practices.

Because safety-testing on these foods is not strict, their long-term effects on our health and on the environment are unknown. Unlike chemical or nuclear contamination, new living organisms, bacteria and viruses will be released into the environment to reproduce, migrate and mutate. They will transfer their new characteristics to other organisms. These changes can never be undone or contained. The effects of genetic mistakes are largely irreversible and irretrievable. Therefore, at this stage - as the Bishops declare in their statement, "It is morally irresponsible to produce and market genetically modified food."

The Major Hazards
3.1 Direct Insertion FURTHER HAZARDS
In their use of recombinant DNA technology, genetic engineers take genes from an organism and inject them into a totally different organism. This is done across all naturally determined species boundaries. This is radically different from cross-breeding, which uses natural reproductive mechanisms, which only combine genetic material from the same or closely related species. For example, by cross-breeding (or hybridising) a variety of maize which is drought-resistant with another variety which produces well, farmers in dry areas can improve their crop. But the product remains maize, and is uncontaminated by other species.

Since a specific function is targeted and transferred to a given organism, gene technology is said to be precise. However, the gene insertion techniques can give unpredictable results, as it is uncertain where the inserted foreign genes will connect with the host organism's DNA, and for each insertion this will be different. Such insertions will in some way destabilise the DNA, cell-function or overall health of the host organism.

Genetic engineering is still a very imprecise science, and scientists concede that they are still very ignorant about DNA. The regulated interaction of genes is very important and complex. This, as well as the role of individual genes within the overall functioning and viability of an organism, is hardly understood.

As Professor Richard Lacey, an expert in food safety, explains, to meet adequate scientific standards, the resulting organism arising from each individual insertion of foreign genes should be tested over a very long period, in the form of a whole food. A small sampling of GM plants of the same kind does not suffice, nor does comparative testing of just some chosen aspects of the total organism's composition.

Even rigorous testing may not ensure safety. The targeted foreign gene function is promoted in the host organism through the agency of yet another foreign viral promoter gene. Such gene activity then works outside the normal regulatory system of the host organism and therefore poses further unpredictable dangers that may manifest over time.

A seemingly successful transfer of a particular function should not be confused with a guarantee that there would be no side effects. For example, Roundup-Ready Soy, the Monsanto company's genetically engineered soybean, has an extra gene to help the plant resist Monsanto's herbicide, Roundup. When Roundup is sprayed on the Roundup-Ready Soy the gene is activated, altering the chemistry of the plant so that it survives the spraying. Since that plant's behaviour is changed, could something in its chemistry also be effected? Could that something be toxic? Perhaps that toxic effect may only become apparent after some years. The immediate survival of the plant does not guarantee that it is safe to eat.

Another important aspect to be kept in mind is the impact of GMOs on the balance of the eco-system. For example, potatoes that have been genetically engineered to resist attack by aphids certainly poison the aphids, but then ladybirds that eat the aphids are also poisoned. Ladybirds are a natural control for aphid populations, so weakening the ladybird population would open the door for the aphid population to grow. Where does the chain end? What are the long-term effects on the ecology? At present, we cannot answer these questions.

3.2 Pollution by Cross-Pollination
Genetically engineered crops can cross-pollinate with nearby natural plants. For example, genetically engineered canola readily cross-pollinates with natural canola and wild weedy relatives up to 2.5 kilometres away. An experiment performed in France demonstrated that the herbicide resistant gene in genetically engineered canola is transferred to wild radishes and persists through at least four generations.

Although bio-technology has the capacity to create a greater variety of commercial plants, the trend set by transnational corporations is to create broad international markets for a single product. This encourages genetic uniformity, thereby narrowing the genetic base of our food resources. Genetic uniformity leads to vulnerability. In the case of the Irish potato famine in the 19^th century, for example, genetic uniformity in the potato crop meant that all the potatoes were susceptible to a single disease. The same potato blight also struck South America, but there the farmers had planted as many as 46 varieties of potatoes; this genetic diversity gave them protection, as the disease affected only a few varieties.

The assumption that we need to create new crop varieties through the use of genetic engineering technologies overlooks the fact that there is untapped potential within the wealth of existing varieties. In Africa, for instance, more than two thousand native grains, roots, fruits and other food plants are found. These have been feeding people for thousands of years, but most are receiving no scientific attention whatever today.

3.3 Herbicides and Pesticides
As crops and weeds naturally begin to develop resistance, and herbicide-resistant traits are transferred from genetically engineered crops to other plants through cross-pollination, higher and higher doses of chemicals will be needed to be effective. Some scientists estimate that herbicide use will triple, resulting in even more chemicals in our food and water. Repeated applications of a single herbicide encourage plants to develop resistance within a very short period of time. Sooner or later, weeds will begin to develop resistance to broad-spectrum herbicides such as Roundup, and more applications of the herbicides will be required.

Since herbicide-resistant GE crops lead to greater herbicide use, the risk of disease for people and animals increases. For example, cancer can result from exposure to high levels of herbicides like bromoxynil (Rhone-Poulenc's Buctril) and glyphosphate (Monsanto's Roundup). Researchers are warning that bromoxynil bio-accumulates because it is fat-soluble. Rat and rabbit studies have shown birth defects, other developmental disorders in foetuses, tumours and carcinomas at levels ranging from twenty to thirty parts per million. Glyphosphate exposure, on the other hand, can triple the risk of non-Hodgkin's lymphoma, say the cancer specialists.
Genetic engineering appears to be replacing chemical pesticide sprays with plants which themselves contain pesticides. Crop plants have now been engineered with the gene for the Bt toxin (Bacillus thuringiensis, a soil bacterium which produces a toxin which is highly valued by organic farmers) to give them an in-built insecticide. In marked contrast to the occasional application of the Bt in organic farming, this transgenic Bt toxin is produced in the plants all the time they are growing. This means that insects are continually exposed to the toxin, and are therefore under constant pressure to develop resistance. Bt resistance has already been noticed among some insect populations. The cultivation of genetically engineered Bt cotton, maize and potatoes could lead to the wanton destruction of Bt, the world's most important biological pesticide. It is ironic that the only natural pesticide available is now under threat of being rendered ineffective.

Little wonder then, that corn and potatoes engineered to produce toxins that kill insects are now classified by the Environmental Protection Agency in the USA as pesticides, rather than vegetables.

3.4 Safety Fears
Safety testing of genetically engineered foods is largely dictated by a concept of 'substantial equivalence'. The supporters of this view claim that a GE crop has similar chemical characteristics to the traditionally produced counterpart. The tests commonly accepted as sufficient to establish substantial equivalence focus on known nutrients, toxins and allergens. The use of substantial equivalence as a basis for risk assessment is seriously flawed, since it focuses on risks that can be anticipated on the basis of known characteristics, but ignores unintended effects that may arise from genetic modification. DNA is nature's blueprint for creating the individuality of an organism. Genetic engineering manipulates an organism at the very source of its uniqueness and changes it fundamentally and essentially.

Genetically engineered food may contain unexpected new molecules that could be toxic or cause allergic reactions. Genetic engineering may transfer new and unidentified proteins from one food into another, triggering allergic reactions. These products are not being thoroughly tested before they arrive on the grocery shelves; they are being tested on people. In the United States, a quarter of all people tested have reported an adverse reaction to one or more foods: dairy products, eggs, wheat and nuts.

For people who are unable to tolerate certain proteins, eating foods containing even traces of these proteins can cause allergic reactions, which may range from minor discomfort to serious illness and even death. In GE, genes are transferred from one organism to another, resulting in the production of new proteins. If a new protein happens to be one that causes an allergic reaction, food that was previously safe for a person could become dangerous for such an individual. The firm Pioneer Hi-Bred International engineered soybeans with a gene from a Brazil nut in the hope that it would improve the soy bean's protein content. Researchers at the University of Nebraska tested these soybeans on samples of blood serum taken from people who were allergic to Brazil nuts. These tests indicated that if these people had eaten the soybean, they would have suffered an allergic reaction that could have been fatal.

Improve or Destroy?
Genetic engineering is a new technology which, according to its promoters, was created to improve food production and increase yields to feed the growing world population. During a meeting of UN Food and Agricultural Organisation in 1998, 24 delegates from 18 African countries representing their respective governments, declared:

"We do not believe that agro-companies or gene technologies will help our farmers to produce the food that is needed in the 21^st century. On the contrary, we think it will destroy the diversity, the local knowledge and the sustainable agricultural systems that our farmers have developed for millennia and that it will thus undermine our capacity to feed ourselves."

According to some studies, none of the GE seeds significantly increase the yield of crops. Examining more than 8000 field trials, researchers have found that Roundup-Ready soybean seeds produced fewer bushels of soybeans than similar conventionally bred varieties. Far from being a solution to the world's hunger problem, the rapid introduction of GE crops may actually threaten agriculture and food security. Widespread adoption of herbicide-resistant seeds may lead to greater use of chemicals that kill weeds. In this way, many non-crop plants used by small farmers in the Third World as supplementary food resources and as animal feed will be phased out. In the United States, the Fish & Wildlife Service has found that Roundup Herbicide already threatens seventy-four plant species.

Biological pollution from GE organisms may be another problem. The agrochemical firm Monsanto is poised to acquire the rights to a genetic engineering technique that renders a crop's seed sterile, ensuring that farmers are dependent on Monsanto for new seed every year. Farming in the Third World could be crippled if these genes contaminate other local crops that the poor depend on. Half of the world's farmers depend on their own saved seed for each year's harvest.

Even if GE were to produce a higher yield, the fact is the world already produces 50% more food than it needs, and yet one in seven people suffers from hunger. This is not because there is a lack of food, but because it is not accessible to them as a result of unjust economic conditions. At the height of the 1984 famine in Ethiopia, for example, oilseed rape, linseed and cotton seed were being grown on prime agricultural land to be exported as feed for livestock to the UK and other European countries. Other products exported to Europe from Ethiopia during the famine included coffee, meat, fruit and vegetables.

The problem however is not just one of distribution. With the massive increase in population in recent decades, there is a corresponding decrease in the amount of agricultural land available. Hundreds of thousands of hectares are being paved over every year by urban sprawl and industrial growth. Another reason for loss of land is degradation of the soil due to erosion, contamination or compaction.

Ecologically-sensitive agricultural systems address these critical issues in various ways: through inter-cropping (planting different crops together); crop rotation; and the cultivation and preservation of bio-diversity. It is possible to improve nutrient-recycling and the preservation of natural resources through the use of cover crops, organic matter such as manures and composts, and the promotion of a healthy soil. Long-term studies of organic farming methods in the USA have produced encouraging results; figures from the first fourteen years show that comparable yields can be obtained without the use of chemical pesticides or fertilisers. It has also been found that yields in organic corn are not reduced as much as conventional corn during drought years, suggesting that the organic systems may be more resistant to drought-stress.

These sustainable agricultural systems are able to provide substantial increases in yields, whilst encouraging the use of local resources and helping communities to become more self-reliant. In contrast, multinational corporations whose business is selling seeds, fertilisers and chemicals, aim to tie farmers to external inputs, which come only from them, at their price. So far the only beneficiaries of the new bio-technologies are the big agrochemical companies.

Patenting
Transnational companies have acquired the right to patent seeds that they have been able to modify genetically. This means that farmers will be tied into contracts to buy both seeds and chemicals, and will not be allowed to plant the farm-saved seed. This is already causing widespread social problems and food insecurity, particularly in developing countries. The patenting of GM seeds will deepen the plight of farmers around the world who are already struggling. If a farmer switches to a genetically engineered seed, that farmer has to sign a gene licensing agreement, which specifies royalty fees and dictates the seed, fertiliser and chemicals to be used. These agreements prohibit the storing of seed for the following season. For example, farmers who grow Monsanto's genetically engineered soybeans sign a contract that opens them to prosecution if they use any herbicide formulations other than the company's Roundup.

This trend towards patenting foods must be rejected. Firstly, it further legalises technology that is harmful to the environment, and thus contradicts the duty of human beings to care for the earth and to ensure that our natural resources are conserved for future generations. Secondly, it undermines the right to food security, which must always take precedence over profits and patents. Food is not just commodity or product like any other, it is fundamental to life itself. The famous comment of the Cree Chief Seattle is appropriate:

"Only when the last tree has died and the last river been poisoned and the last fish been caught will we realise we cannot eat money".

Currently 80% of the patents on GM foods are owned by just 13 transnational corporations (TNCs). Like other forms of intellectual property rights such as copyright and trademarks, patents are a form of incentive and reward for inventions. Such rights have traditionally been associated with non-living inventions in industrialised and market-based economies, and have been little used in agriculture. But companies engaged in bio-technology have been pressing for the adaptation of classical intellectual property law to cover life forms, as being no different from any other form of technology. In 1985, the US Patent & Trademark Office allowed genetically modified plants, seeds and plant tissue to be patented. The patenting of any life forms, modified or not, should be contested. Corporations can engage in 'bio-piracy', by acquiring the knowledge of generations of indigenous farmers, and then, after subjecting this knowledge to scientific analysis, taking out patents on the resulting product. We know that each 'improvement' in farm crops, whether by hybridisation or genetic modification, tends to reduce bio-diversity and to marginalise those crops which in the present agricultural and economic context are regarded as unprofitable. These varieties are also the traditional crops on which the poor depend.

Care of the earth, according to an attentive interpretation of what the Bible (Genesis Chapter 2) tells us, includes not only the responsible use of creation, but also its preservation. A turning point occurred when patent applications involving living organisms began to be filed on a regular basis. There has to be a distinction between living and inanimate things. Firstly, animals and plants are creatures that have a life of their own. They are not products of industry or mere objects for human use. Secondly, the addition of two or three genes to an animal with perhaps a hundred thousand genes does not turn the animal into a human invention. An animal, plant or micro-organism owes its creation ultimately to God, not to human endeavour. In genetic engineering, moreover, only a tiny fraction of the make-up of the organism can be said to be a product of the scientist. The organism is still essentially a living entity, not an invention. Despite the considerable investment involved, the identification of a gene's function is not an ethical ground for claiming exclusive rights. Even though intellectual effort has been used, it is of the nature of discovery, not of invention.

LabellingLABELLINGLABELLING
Everyone has the right to choose what to eat, and therefore, to know what is contained in the foods offered for sale. At this stage in South Africa, foods that have been genetically engineered are available on the supermarket shelves together with other products, with no distinguishing label. Most processed food imported from USA and Europe contains genetically engineered ingredients, mainly soya oil, lecithin, canola and corn syrup. It should be noted that milk on South African shelves may contain genetically modified bovine growth hormone, known to cause cancer in humans and mastitis in animals. Without labelling, consumers lose their freedom to choose what they will eat and feed to their families. We have all become guinea pigs in a highly controversial and dangerous experiment.

International agro-chemical companies adamantly oppose the labelling of GE foods, on the grounds that this will scare off people from buying them. At the very least, genetically engineered foods must be labelled so that we can choose for ourselves whether we will eat them or not. It is urgent that laws be approved in order to mandate the clear and accurate labelling of all foods derived from, processed with, containing or consisting of genetically engineered organisms before they are released into any and all commercial markets. Labelling must be clear, visible and understandable to all. In addition, many people suffer from various kinds of allergies caused by the food they eat; accordingly, all products should be labelled with information that allows allergy-sufferers to make a safe choice.

Only the experience of extensive laboratory experiments and carefully controlled field trials over a long period of time will provide any realistic basis for a broad claim of the safety of GE food. A precautionary 'safety-proven' policy cannot be sacrificed in favour of corporate financial interests. "The bottom line" says American toxicologist Susanne Wuerthele "is that we are confronted by the most powerful technology the world has ever known, and it is being rapidly deployed with almost no thought whatsoever to its consequences."

The five-year moratorium is needed precisely to enable this thought to take place. Responsible experimentation during such a period would at least allow us to assess more accurately the effects of GE on consumers, farmers and the environment itself.

Signs of Hope
In 1996 in Germany the physicians' association issued a statement demanding the labelling of GE foods. Germany has banned Novartis Bt maize. The initiative "No GE on communal land" of BUND (Friends of the Earth, Germany) is active in several German communities, promoting discussion and voting on 'GE-free' resolutions. Several Protestant Church organisations have banned GE crops from their land.

In Austria in 1997 the Government stated that it wanted to be a "Biotech-Free Zone". Austria has banned three varieties of GE maize.

In Norway an Act was passed prohibiting the release of genetically modified corn, tobacco, chicory and rape-seed, stating that anti-biotic resistance was already a serious enough problem without adding anti-biotic resistant genes into the food supply. Norway has imposed a ban on the import of six GE crops and products that contain anti-biotic resistance. Thirty-one applications have been rejected to date.

In England, Iceland Frozen Foods, the fourth largest retailer in the country and largest manufacturer of England's frozen food supply, announced in 1998 that its in-house product line would be made without GE ingredients, and all its other products would be labelled. The Church of England has refused permission for GE crop trials on 60 000 hectares of its land. Dozens of local authorities supply GE-free school lunches and the House of Commons has banned GE food from its catering.

In Italy there are bans on GE crops in four regions and twenty-five provinces.

In Japan in 1997 the leading food retailer initiated plans to label GE foods in its stores. Members of the Japanese dairy industry decided not to import cheeses that contained Chymosin, the genetically engineered cheese enzyme, stating that Japanese consumers were not ready for genetic engineering.

Denmark will spend five hundred million US dollars over ten years in a programme aimed at the creation of 100% organic agriculture.

Since December 2000, Algeria has banned the import, distribution, commercialisation and utilisation of GE plant material.

Egypt has decided not to import GE wheat.

Saudi Arabia has banned GE food and will not import GE wheat.

Sri Lanka has banned the import of all GE foods from May 2001.

The Chinese Government banned the commercial planting of GE rice, wheat, corn and soybeans.

Australia has banned GE rape-seed in Tasmania, and has banned commercial planting of GE crops in Western Australia (Australian States have been given the right to declare themselves GE-free).
In New Zealand the Government has blocked trials of GE salmon. Some local bodies in Wellington and Auckland have declared themselves GE-free.

The South African Situation
The present South African legislation, Act 15 of 1997 (GMO Act), is internationally recognized as being completely inadequate to control GE applied to agriculture and food production. The GMO Act and the Regulations of the GMO Act issued by the Department of Agriculture in 1999, do not offer any protection for farmers or consumers with respect to negative livelihood, environmental or health consequences. The current legislation also provides exemptions from permitting requirements for almost all genetically modified seed, food or animal feed. Academic and research facilities too are exempt from permits.

Furthermore, in the GMO Act there is a total absence of the "polluter pays" principle embodied in National Environmental Management Act (NEMA, 1998). Up to now South Africa has not yet signed the Bio-safety Protocol (1999) providing for strict bio-safety liability when moving GM organisms and material internationally.

In view of these widespread concerns, and given our lack of knowledge about the long-term effects of GE, the following questions arise for South Africans:

_Â Â Â Â Â Â Â Â Â What signs of hope have we in South Africa?

_Â Â Â Â Â Â Â Â Â Could the Government share with the nation the steps that have already been implemented to eliminate the negative effects of this new technology on health and environment?

_Â Â Â Â Â Â Â Â Â What measures have been enforced to label accurately local and imported foodstuffs?

_Â Â Â Â Â Â Â Â Â What percentage of National Budget is allocated annually to:
_Â Â Â Â Â Â Â Â Â promote organic agriculture
_Â Â Â Â Â Â Â Â Â protect our biodiversity
_Â Â Â Â Â Â Â Â Â promote and protect traditional farming systems

We appeal to our Government to take seriously the plea of the Southern African Catholic Bishops Conference (cf. November 2000 statement) who are calling for a moratorium on GE crops and foods, in support of the campaign launched by the South African Freeze Alliance on Genetic Engineering (SAFeAGE).

The Justice & Peace Environment Desk
Southern African Catholic Bishops' Conference
PO Box 941
Pretoria
0001

Contact Person: Fr Efrem Tresoldi
Tel: (012) 323 6458
Fax: (012) 325 6125

Appendix 2


TO THE PORTFOLIO COMMITTEE ON ENVIRONMENTAL AFFAIRS AND TOURISM

FROM THE SOUTHERN AFRICAN CATHOLIC BISHOPS' CONFERENCE

SUBMISSION ON GENETICALLY MODIFIED ORGANISMS (GMOs)
Re: Concern over the speed with which GM Technology has been and is planned to be introduced in South Africa


1. INTRODUCTION
LADIES AND GENTLEMEN
I thank you the opportunity to present the concerns we have over the rapid introduction of GM food, seed and technology without prior information and education of the vast majority of the SA people.

I open my presentation with a quote from the American toxicologist Susanne Wuerthele:
"THE BOTTOM LINE IS THAT WE ARE CONFRONTED BY THE MOST POWERFUL TECHNOLOGY THE WORLD HAS EVER KNOWN AND IT IS BEING RAPIDLY DEPLOYED WITH ALMOST NO THOUGHT WHATSOEVER TO ITS CONSEQUENCES."

2. WHAT IS GENETIC MODIFICATION?
The deoxynucleic acid strand (DNA) in the nucleus of all living cells is the chemical blue print of all processes that will assist the cells and the whole organism to function and be what it is. Genetic modification, through the insertion of genes non specific to the organism, plant or animal now modifies this blue print in ways that are largely non predictable. Also, viruses, etc. are used as carriers for these foreign genes to get inserted into the DNA strand. These carrier viruses remain part of the nucleus and therefore will, in unknown and unforeseen ways, interact with the chemistry of the cell.

3. SUBSTANTIAL EQUIVALENCE
The American FDA claims "substantial equivalence" between conventional and GM food.. SA adopts this position at present. There is no possibility of equivalence because never before have people introduced into the food chain components that have never been used as food in nature or interfered with the very blueprint of life. Therefore, we cannot compare this GM food with conventional food. It is only prolonged observation that will allow our experts and the people to decide whether to engage on a large scale with food production involving GM. You might also know that American scientists who warned FDA of inadequate testing of GM food were ignored. These scientists are now suing the FDA.

4. REDUCTION OF THE USE OF INSECTICIDES
Contrary to the promise of multinationals and the need and hope of American and Canadian Farmers, the use of insecticides needed for GM crops has sharply increased. Triple herbicide resistant weeds and insect resistance are being widely noted. According to research reported in the US Agronomy Journal, 3 2001 yields from GM soybean are 5-10% lower and use 30% more herbicide than conventional soybean. In addition, the US market share on soybean has decreased because of increasing rejection of GM food and feed.

5. ENVIRONMENTAL CONTAMINATION
Cross-pollination has been proven between GM and non GM crops and between GM crops and the wild relatives of agricultural plants. A super weed, a relative of GM Canola has emerged, which farmers find very difficult to control. Cross pollination between GM and non GM crops destroys the livelihood of organic farmers, the national seed security and threatens the genetic resource that wild relatives of agricultural plants represent. This aspect is very important for Africa because of our rich bio-diversity. In addition, pollinating and helpful insects are affected severely. Introduction of GM crops on a large scale will lead to irreversible genetic contamination of the environment.

6. SEED SECURITY
Many American and Canadian farmers wish to return to the use of conventional seed, but find this difficult because much seed has been contaminated. USDA has recently granted Pineland and Delta the right to use and sell seeds that have been rendered sterile, i.e. are able to germinate only once. This introduced sterility can spread and cause the extinction of many plants and animals. Together with genetic pollution, it can lead to the loss of indigenous types of crops that, through having developed in the dry soils of Africa, are well adjusted to feed us in the dry climate predicted for our continent as a consequence of climate change. Rural and poor people have always saved seed for the next season. Introduction of sterile seed will render the country dependent on the transnational seed companies and remove our hope as a nation and that of many farmers to survive through our own knowledge and remain seed secure. It will destroy the work and the knowledge of 2.5 billion of poor people globally.

7. ETHICAL ISSUES
Unlabelled food containing genes from animals not eaten by religious groups is a violation of their freedom and right.
Avoiding GE food is impossible, especially for the poorer sections of the population .who rely on cheap processed food.
As believers, we are asked to care for creation. This demands that we move with utmost care with processes able to destroy the future of the earth and of many of her children.
Ethical judgements are not the right of universities or appointed panels but of a well and correctly informed people of a country and those mandated by them after prolonged and open debate.

8. ECONOMIC ISSUES
18 transnational companies, mostly in the US, own 80% of the patents related to GM terminology, of which only 3 are involved with GM seed related technology. Of these, Monsanto owns over 60% of the production. Their interests are not in the welfare of the people but in recouping the money used in the research and in making profits. This is made apparent by the development and introduction of terminator technology and the stringent conditions attached to the use of their seed.

SA will lose export markets as more and more countries and farmers move away from the use of GM food or minimise the percentage of GM food permissible for their imported food. We would be well advised to use the R182 million planned to fast track the introduction of GM into SA for job creation and rehabilitation of the land.

9. FOOD SECURITY
During the past years the production of food has outstripped population growth by 16%. Every year the US disposes of 48 million tons of good food to keep prices high. Organic farming has increased production of quality food while rehabilitating the land from the ravages of the green revolution. Clearly, we do not need GM crops to feed an increasing world population.

A fraction of R182 million made available for the introduction of organic food production in the rural areas would render our rural farmers self-reliant and safeguard our biological resources.

India, through land reform and irrigation has increased its food production by 50% and Cuba has raised its agricultural output by 40% within the last few years without the use of GM technology. The many patents on GM organisms relating to food and animal feed transfer control over food security from the Government to foreign, especially American multinational companies.

10. PETITION
For the above reasons, we ask that
Any further introduction of GM in food and crop production be halted immediately; and existing processes be terminated UNTIL RESEARCH HAS CLEARLY DEFINED RISK AND ADVANTAGES OF GM PROCESSES; AND SA PEOPLE HAVE BEEN INFORMED TO MAKE THEIR CHOICE;
that the polluter pays principle be applied to all GM processes;
that complete labeling of food be immediately introduced;
that the public be educated on the risks of GM food, crops and seeds;
that all research results related to the application of GM technologies be accessible freely;
That SA sign the Cartagena Protocol (Bio safety protocol ) with urgency.

11. CLOSURE:
I wish to close with a declaration of 24 delegates representing 18 African countries
to the UN Food and Agriculture Organisation:

"WE DO NOT BELIEVE THAT AGRO-COMPANIES OR GENE TECHNOLOGIES WILL HELP OUR FARMERS TO PRODUCE THE FOOD THAT IS NEEDED IN THE 21^ST CENTURY. ON THE CONTRARY WE THINK IT WILL DESTROY THE DIVERSITY, THE LOCAL KNOWLEDGE AND THE SUSTAINABLE AGRICULTURAL SYSTEMS THAT OUR FARMERS HAVE DEVELOPED FOR
MILLENIA AND WILL THUS UNDERMINE OUR CAPACITY TO FEED OURSELVES."

Contact Persons:
Sr Angelika Laub
SACBC Justice & Peace Eco-Group
Phone & Fax: (011) 949 1291

Fr Efrem Tresoldi
SACBC Justice & Peace Department
Phone: (012) 323 6458
Fax: (012) 326 6218

Appendix 3
Presentation to the Parliamentary Committee on Environmental Affairs and Forestry - Hearings on GMO's - Tuesday 30 October 2001

Madame Chair, honourable members, ladies and gentlemen,

I would firstly like to thank the members of this portfolio committee for the consistent commitment you have shown to looking into this issue. It is an issue that cuts across various departments including the Departments of Agriculture; Health; Trade and Industry; Arts, Culture, Science and Technology; Water Affairs and Forestry and Fisheries and I thank you for inviting members of those departments here today.

I represent the South African Freeze Alliance on Genetic Engineering (SAFeAGE), a network of organisations and individuals concerned about the effects of genetic engineering on our health, environment and food security. Currently 127 South African Organisations including the FAWU, Earthlife Africa and other environmental organisations, educational institutions and faith based organisations and 1341 South African individuals have endorsed our call for a minimum five year moratorium on genetic engineering and patenting in Food and Farming in South Africa.

We are concerned about a number of issues including the long-term health impacts of genetically engineered foods; environmental safety issues, loss of biological diversity, food security, adverse effects on trade and the socio-economic effects on our farmers.

In order to address these issues there are a number of actions that we believe can be taken. These suggestions have come out of research by legal consultant Mariam Mayet for Biowatch and others. They are a starting point from which we can together look at this highly complex and controversial issue.

Our first suggestion is that a national policy on genetic engineering is urgently required to address the multi-faceted and controversial issues concerning genetic engineering in food, agriculture and forestry.

The process of drawing up a national policy needs to be consultative and transparent. NGO's, business, farmers, unions and consumers need to be involved in the process. It should, as it's first task, undertake a comprehensive cost-benefit analysis, by comparing genetic engineering with other technologies that are currently being applied in South Africa and investigate how best to ensure access to adequate food by the poor.

A national policy should address various issues including;

The impact of transgenic seed on food production systems and food security;
The impact of genetic engineering on traditional and indigenous technologies;
The impact of intellectual biotechnology property rights on sustainable agriculture and food security;
The impact of genetic engineering on South Africa's agricultural export market;
The impact of genetic engineering on productive traditional farming systems and local rural economies;
The impact of genetic engineering on the environment, particularly biodiversity and ecosystems and genetic contamination;
The role and future of organic agriculture
Consumer choice and public participation
The impact of transgenic food on human health and safety
The implications of genetic engineering for animal health and welfare
Guidelines for state supported biotechnology research
Ethical and religious considerations and sensitivities

Such a national policy will also give us a policy framework within which to work on this issue and come up with realistic, working solutions.

Secondly, we would like this portfolio committee to urge the government to sign, ratify and implement the Biosafety Protocol as soon as possible. Ratification of the Protocol will mean that the GMO Act would have to be substantially amended in order to give effect to the provisions of the protocol. At a previous meeting I attended with this committee on 8 May 2001 we were informed that when the GMO Act No 15 of 1997 was drafted, the issue of revisiting it was emphasised as this is an extremely fast moving technology and it's implications were only and in fact are still only beginning to be understood. A team of prominent independent environmental and human rights lawyers scrutinised the GMO Act and came to the conclusion that the legislation showed "a cynical disregard for contemporary international and national environmental principals as well as for the development imperatives for South Africa".

Four years have now past and despite this damning review (the findings of which have been submitted to this committee), no revisiting has been undertaken. During that time over 200 permits have been granted for field trials for a variety of crops including, maize, soya, potatoes. tomatoes, apple and canola. In addition to this genetically engineered maize and cotton have been commercially released with potentially grave environmental consequences including the possible contamination of our non-GE crops. By not taking action in this regard we are complicit in allowing this technology to be applied unchecked without having fully understood the danges. Already there have been economic consequences as a result of our growing of genetically engineered maize - Namibia's beef industry relies on European markets who will not accept cattle fed on GE maize and South African maize has been turned back from Namibia for this reason.

Thirdly we are aware that the Department of Environmental Affairs and Tourism is in the process of reviewing the Environmental Impact Assessment Regulations and we urge this portfolio committee to ensure that the provisions relating to genetically modified organisms (GMO's) will receive urgent attention. To our knowledge, not a single risk assessment, environmental impact assessment or socio-economic impact assessment of agricultural biotechnology has been undertaken by the South African government. This is deeply concerning given the potential dangers and unforeseen consequences of this technology.

Fourthly, urgent policy decisions must be made regarding the institution of specifically tailored and appropriate measures for safety testing of GMO's and products of GMOs in South Africa under South African conditions.

Fifthly the Department of Health should urgently finalise, through a process of participation and consultation, the draft regulations requiring the mandatory labelling of GMOs and products derived from GMO's. Informed South African consumers, like other consumers around the world including Japanese, European and Brazilian are concerned about the long term health and safety effects of genetically engineered foods. This accounts for the extraordinary growth of the SAFeAGE alliance which is made up of grassroots membership. The labelling of genetically engineered foodstuff is essential in guaranteeing consumers right to choose what they wish to consume. It also allows GMO's to be traced through the food chain.

I believe that what we have presented outlines practical steps that can be initiated by this portfolio committee. The South African Freeze Alliance on Genetic Engineering believes that five years is the minimum time needed to accomplish these tasks. We are therefore calling on the government to introduce a minimum five-year freeze on:

The growing of field trial or commercial GE crops until GE is proven safe, environmentally harmless and in the interests of the people of South Africa and her neighbours;
The import and export of GE foods and farm crops;
Patenting genetic resources for food or farm crops

We do not believe that the people of South Africa should bear the environmental and economic risks of this highly contentious technology while all the short-term returns accrue to a handful of opportunistic foreign companies. South Africa may suffer the long-term consequences of this technology long after the profits have been repatriated. We know from the example of the tobacco companies that the long-term interests of the people do not necessarily co-incide with the short-term unconstrained profit-maximising behaviour of companies. Many countries around the world have looked at this risk-return trade-off and said 'No'. We believe that South Africa should say the same at least until the risks are fully understood and the practical steps taken to mitigate these.

Appendix 4
Green Party; Submission to parliamentary select committee on GMO's

Thank You Mme Chair. My name is Glenn Ashton and I represent the Green Party of SA. I am internationally regarded as an expert around the issues of GMO's and intellectual property.

Firstly, I would like to ask why the government so intensely questions the HIV/AIDS dogma but conversely embraces the hype around GMO's? The issues are very similar in many ways; both deal with the issue of control of points of view by extremely powerful commercial interests; both revolve around the health of our nation; and both are intimately connected to the issue of patents and corporate control.

For the sake of consistency I plead with the government of this nation to look beyond the narrow dogma that we need GMO technology to feed and uplift our people. This claim is false and is nothing less than moral blackmail by some of the most powerful corporations in the global agribusiness industry. If we are going to question the AIDS/HIV dogma, we must equally question the issue of GMO crops and biotechnology generally.

Biotechnology has been presented as something that can bring great benefits to the world. This is true, but so too can it bring equally great problems. The global realisation that simple biotechnology techniques can be used for purposes of terrorism or warfare is only now reaching our consciousness. What research or thought, has been given to the impacts of GMO's in even 20 years time?

The sale of two of South Africa's largest seed interests to the Monsanto Corporation, one of the world's biggest agrochemical multinationals, should ring some alarm bells. The fact that their patent on Roundup or glyphosate weedkiller, expired last year, coupled to the fact that they specialise in crops that have a genetic protection to this chemical and where contracts tie the use of their seed to the use of this chemical, should raise some questions.

The use of this technology is globally connected to the rise of herbicide resistant weeds. For instance in Canada, certain weeds are now resistant to three types of popular herbicide through cross pollination and contamination by GMO's and instead of reducing the use of powerful chemicals, as claimed, this technology increases the use of even more potent chemical cocktails. This is a technology developed for northern, first world uses, that has been made unwelcome in Europe, the East and elsewhere, and which is now being dumped in Africa.

We also have deep concerns over a lack of oversight of GMO crops in SA. The government departments responsible for divulging this information have been extremely tardy and reluctant to share any information about the siting of these crops in SA. This issue has been raised before this very committee previously but no discernable progress has been forthcoming. If these details are not made public it is exceptionally difficult for civil society, already constrained by a lack of historical capacity, to monitor these trials and large-scale plantings. (We have been unable to monitor separation distances, amounts of refuge planted or obtain any other meaningful data. It is also questionable whether the state has the capacity to monitor these critical issues; if it has we would like very much to have access to this data. Given, for example the demands placed on the Dept of Agriculture by the recent foot and mouth outbreak, it is clear that extension and inspection services are massively overextended.)

Leading on from this lack of capacity, concerns arise as to what research has, or is being done into impacts of this technology on our biodiversity. Given that we are entering the third phase of corporatisation, the first being exploitation of human resources, the second of mineral resources and the third of biological resources, it is essential that our natural genetic capital is actively protected.

It seems that the state has not grasped the gravity of the situation. In an age where genetic information is the new capital upon which fortunes will be made, and in a nation where we have a treasure trove of biodiversity, neither the people nor the state has given any indication that there is any understanding of the magnitude of the importance of this issue. Even the recently published Biotechnology strategy paper gave this issue little more than lip service and clearly did not get it. The fiasco of the National Botanical Institute/Ball Corporation deal covered in the media shows that nobody, except the corporates, has a handle on exactly how important our genetic capital really is. The bias toward corporatisation of our natural heritage should be raising bigger questions than the privatisation of our parastatal corporations. (The tragedy is that a real understanding of this issue will only come to our children but we must make a start.)

The Green Party supports our many advances in biotechnology, microbiology and genetics in SA. However, we are extremely worried that our government is being taken for a ride by powerful corporate interests that run directly counter to our national interest. Present GMO technology is not about feeding our nation or Africa; it is about the cynical control of the global food supply and biological capital. As I said at the start; if we are going to examine the HIV/AIDS orthodoxy, then we must equally examine the far more profound questions raised by this new genetic frontier.

(If this government is serious about the food and welfare of the nation I can offer at least 10 more powerful alternatives to GMO's that carry none of the dangers of this new and inadequately examined technology. Lets explore the real alternatives that the present emphasis on GMOs eclipses.)

Finally, We call for a commission of enquiry into the ramifications of the exploitation of, and the dangers to, our natural capital. Failure to institute this commission, and assume into law its findings, will be calamitous to the national interest in the short, medium and long term.

Thank you.

18 alternatives;
Mixed cropping (intercropping), permaculture principles, push pull processes, drip irrigation, mulching, multiple cultivar plantings, organic farming, improvement of soil tilth, increasing soil microbia, nutrient cycling, education, networking with established farmers, urban food gardens, land redistribution, raising indigenous crops in intensified natural conditions, integrated pest management; more available on request.