Implications of Commercial Release of GM Maize in México

THIRD WORLD NETWORK BIOSAFETY INFORMATION SERVICE

 

Dear friends and colleagues,

 

The Mexican government may soon approve the large-scale release of GM maize for commercial production (see BIS ‘Serious concerns over possible approval of large-scale planting of GM maize in Mexico’, 20 November 2012).

 

The Union of Concerned Scientists from México (Unión de Científicos Comprometidos con la Sociedad de México, UCCS) has sent a letter to the President and President-Elect of México, urging them to take all necessary measures to guarantee that no transgenic maize is released in the center of origin and diversity of this essential food crop (Item 1).

 

The letter is accompanied by a briefing document (Item 2) that introduces and analyzes the key issues and the potential implications that approval of GM maize in México may have for food security, agricultural biodiversity and the right to food. The briefing is endorsed by UCCS, Third World Network, European Network of Scientists for Social and Environmental Responsibility (ENSSER), GRAIN and International Network of Scientists and Engineers for Social Responsibility (INES).

 

The briefing concludes that the potential impacts threaten the right to maize as a vital food. It strongly urges the Mexican authorities to implement the activities specified below, in order to first create necessary broader dialogue, and a collective re-think of the wisdom of large-scale release of GM maize into the epicenter of maize agrobiodiversity:

 

* Take into consideration the work of 235 experts from 70 institutions coordinated by the Mexican biodiversity commission (CONABIO) that designates México as the center of maize diversity containing the centers of origin and domestication.

 

* Amend the Regulations of the Mexican Biosafety Law, so that the Special Protection Regime for centers of crop origin and diversity, particularly for maize, is enforced.

 

* Stop the processing of any application for open-field release of GM corn in México.

 

* Reject permits for commercial planting of transgenic maize and cancel all existing permits for “pilot scale” and “experimental scale” releases of GM maize into the environment on the basis of the scientific evidence documenting the extent of transgene flow and the center of origin and diversity of maize in the entirety of the Mexican territory.

 

* Begin an immediate transparent and open peer-review of the environmental and social aspects of GM maize cultivation in México, based on thorough scientific criteria and public engagement, utilizing a set of criteria and standards that are scientifically, socially and environmentally acceptable. Such a process should consider the alternative options to address issues of food production in México and include representatives of peasant and indigenous maize production of communities throughout México, whose livelihoods may be impacted by the introduction of GM maize in the country.

 

* Conduct a thorough and transparent review and public consultation of the acceptability of the existing policies surrounding GM maize agriculture in México.

 

For many issues and instances investigated by the briefing, the evidence is solid and clear, for others, critical uncertainties over potential impacts remain. Taken together, UCCS argues that this gives a legitimate justification to require a precautionary policy that prohibits the commercial level releases of GM maize in its center of origin: México.

 

 

With best wishes,

Third World Network

131 Jalan Macalister

10400 Penang

Malaysia

Email: twnet@po.jaring.my

Website: www.biosafety-info.net and www.twn.my

Item 1

 

November 26th, 2012

 

To the President of Mexico, Lic . Felipe Calderón Hinojosa

To the Elected President of Mexico, Lic. Enrique Peña Nieto

To the Biosafety Authorities of the Government of Mexico


P r e s en t

 

In 2009, we sent the President of México, Lic. Felipe Calderón Hinojosa, a formal statement (http://www.uccs.mx/doc/g/sciencetrmaize_es) reminding him of his utmost responsibility to safeguard one of the world’s most precious resources for food security: Mexico’s maize diversity. However, we observe that his administration has continued to promote the introduction of genetically modified (GM) maize in México, despite legitimate concerns over the broad implications of this decision. We find that the process to approve the large-scale release of GM maize into the Mexican environment, nearing completion for the first round of applications, has been procedurally deficient, and conducted with undue haste.

 

Joined together by scientists, academicians and citizens around the world, we draw attention to the scientific evidence that supports prudent precaution and foresight for such a momentous decision, given the potentially irreversible adverse impacts GM maize in México may have on maize agricultural biodiversity, farmer livelihoods and the right to food – not only for México, but maize farmers and consumers around the world.

 

Bound by a sense of ethical duty to preserve this critical resource for humanity, and at the heart of the Mesoamerican culture, we demand that the administrations of President Felipe Calderón, as well as that of the elected President, take all necessary measures to guarantee that no transgenic maize is released in Mexico, the center of origin and diversity of this essential food crop.

 

These measures are justified scientifically, as we have summarized in a Call to Action statement from our organization, the Union of Concerned Scientists from Mexico (Unión de Científicos Comprometidos con la Sociedad de México) that was publicly presented on November 15th of 2012 (http://www.uccs.mx/doc/g/planting-gmo-corn). This statement (which as of this date has been signed by over 2000 academicians and scientists, including Nobel laureates, Mexican national prize winners in science and other concerned citizens around the world) rejects the planting of GM maize in Mexico, and alerts on threats to maize in its center of origin and diversity; as well as on the potential risks to human health of that may result from large-scale releases of GM maize in Mexico. Through this Call to Action we will continue to seek support and inform the academic and scientific communities of the necessity to protect maize agricultural biodiversity.

 

Meanwhile, we have continued our investigations concerning the potential impacts of large-scale GM releases by reviewing and analyzing from the recent scientific and academic literature, the evidence that will continue to support our views. Further, we are synthesizing new evidence linked to the risks and also benefits of GM crops. This work is being carried out by a multi-disciplinary team of experts from the USA, Europe, Latin America and Asia. We have attached along with this letter, a briefing document that summarizes the outcomes of our analysis as conclusions to date, and the need for further investigation to clarify some critical uncertainties that may arise from the large-scale commercial release of GM maize in México.

 

This report, entitled, "GM (genetically modified) maize in Mexico: An irreversible path away from agricultural biodiversity, farmer livelihoods and the right to food within the center of origin of maize", originally written in English in order to reach the international community, has been endorsed by well-recognized networks of scientists and academics, and internationally recognized non-governmental organizations concerned about the impacts of technological developments on society and the environment around the world: Unión de Científicos Comprometidos con la Sociedad (UCCS), European Network of Scientists for Social and Environmental Responsability (ENSSER), Third World Network (TWN), GRAIN and the International Network of Engineers and Scientists for Global Responsability (INES).

We will continue to make our report open for endorsement from other such networks and organizations.

 

For many issues and instances we investigated, the evidence is solid and clear, for others, critical uncertainties over potential impacts remain. Taken together gives a legitimate justification to require a precautionary policy that prohibits the commercial level releases of GM maize in its center of origin: Mexico. In the brief, we elaborate some of the critical uncertainties, inadequacies and unfulfilled promises of GM crops already cultivated for more than 16 years, clearly demonstrating that the track record of GM crops, and the documented consolidation in seed markets in countries that have adopted them, suggests that GM maize is not a viable agricultural development blueprint for México to follow.

 

We illustrate with two examples: 1) Uncertainties regarding the long-term effect on human health from the consumption of GM crops in a country such as Mexico, where large quantities of maize are consumed with very little processing, and 2) socioeconomic and legal implications that may result from the inadvertent infringement of intellectual property rights (IPRs) resulting from GM and non-GM maize hybridization. Further, our analysis noted a critical lack of transparency and information as to the identity and origin of maize "pedigrees" or lineages used by the GM maize developers and adapted for the Mexican environment. We question whether the GM maize hybrids adapted to the Mexican agroenvironment, for which commercial release in Mexico is being sought, may contain native “criollo” native varieties that were originally created for the common good, but may be now in the process of being patented and privatized. We will continue to investigate this critical issue, and other related questions that are not readily available for informed public consultation.

 

This letter and attached brief are being circulated throughout the entire world via the networks of scientists who are concerned with the social and environmental consequences of technological developments, and to the press. We will keep you informed of our continued analysis through the relevant academic institutions and scientific organizations, and invite you to contact us with any questions or needs of assistance.

 

We look forward to a prompt response to this serious issue.

 

Sincerely,

 

Item 2

UCCS, TWN, ENSSER, GRAIN, INES

 

The Mexican government stands on verge of approving the large-scale release of genetically modified maize for commercial production. The continued government policy promoting genetic modification in maize, despite earlier warnings from the Mexican scientific community, stands in contrast to a chorus of legitimate concerns stemming from unanswered scientific, legal, social and economic questions over the implications for food security and the right to food concerning the adoption of agriculture using genetically modified crops at centers of their origin and diversity.

 

This is a decision whose importance and impacts are difficult to understate: A potentially irreversible impact on Mexican maize, that is at the heart of the Mesoamerican culture, that is also the staple food of Mexicans and millions more; a threat to our food and health, as well as to the indispensable communal way to create and maintain maize diversity in front of the interest of large corporations to privatize and control the maize seed market, that would make maize producers depend on such corporations, would threaten the right to save seed, and would diminish agricultural biodiversity and destroy the millenarian culture associated to maize and its diversity; finally all this would negatively affect maize consumers all around the world and global food security hindering the possibility of facing the challenges posed by a changing climate.

 

This brief introduces and analyzes the key issues and implications that approval for large-scale releases of GM maize in México may have for food security, agricultural biodiversity and the right to food. During our research we encountered severe deficiencies in the rationale and

 

 

A pro-forma public consultation period in México of requests for commercial-scale planting of GM maize has just finished as the last procedural hurdle on the path to approval, despite all previous efforts to convey. We conclude that the potential impacts threaten the right to maize as a vital food. Furthermore, given the biological irreversibility at hand, we therefore strongly insist and urge the Mexican authorities to implement the activities specified below, in order to create necessary broader dialogue and a collective re-think of the wisdom of large-scale release of genetically modified (GM) maize into the epicenter of maize agricultural biodiversity.

 

•         Take into consideration the work of 235 experts from 70 institutions coordinated by the Mexican biodiversity commission (CONABIO) that designates Mexico as the center of maize diversity containing the centers of origin and domestication (http://www.biodiversidad.gob.mx/genes/proyectoMaices.html; Kato-Yamakake et al., 2009).

•         Amend the Regulations of the Mexican Biosafety Law, so that the Special Protection Regime for centers of crop origin and diversity, particularly for maize, is enforced.

•         Stop the processing of any application for open-field release of GM corn in México.

•         Reject permits for commercial planting of transgenic maize and cancel all existing permits for “pilot scale” and “experimental scale” releases of GM maize into the environment on the basis of the scientific evidence documenting the extent of transgene flow and the center of origin and diversity of maize in the entirety of the Mexican territory.

•         Begin an immediate transparent and open peer-review of the environmental and social aspects of GM maize cultivation in México, based on thorough scientific criteria and public engagement, utilizing a set of criteria and standards that are scientifically, socially and environmentally acceptable. Such a process should consider the alternative options to address issues of food production in México and include representatives of peasant and indigenous maize production of communities throughout México, whose livelihoods may be impacted by the introduction of GM maize in the country.

•         Conduct a thorough and transparent review and public consultation of the acceptability of the existing policies surrounding GM maize agriculture in Mexico.

 

 

In 1999, after an experience of 11 years on biosafety, the Mexican government following the scientific advice of a panel of experts, placed a de facto moratorium on the cultivation of genetically modified (GM) maize to safeguard México’s cultural and natural heritage (patrimonio cultural y natural) (Serratos-Hernández 2009) –the rich maize agricultural biodiversity at its center of origin and diversity of maize. Mexico, as the global steward of this vital resource, has a unique and important responsibility to preserve this genetic diversity for the breeders and farmers around the world to respond to the challenges of food security, including those posed by climate change, as well as to guarantee a diverse and healthy offer of maize products, but also to guarantee Mexico ́s food sovereignty, being maize the staple food of this country.

 

In 2005, the Mexican Biosafety Law (LBOGM 2005) was enacted that in effect removed the moratorium –despite the situation that motivated it in the first place remained unchanged— and instead formalized a path for the approval of large-scale commercial cultivation of GM crops within its borders. Since 2009, the Mexican biosafety commission (CIBIOGEM) has given approval for 177 small GM maize field trials to four transnational companies (Dow AgroSciences, DuPont, Monsanto and Syngenta). These trials were nothing but reiterations of previously evaluated trials on which the de facto 1999 moratorium was based. Hence, results from such trials, if anything, should have confirmed the reasons to establish such a moratorium. In contrast, and without making a formal and public presentation of such trials ́ results, at the moment, three multinational corporations are in the final stages of seeking approval for the wide-scale release of patent-protected transgenic maize varieties in México – a decision with potentially irreversible implications for the heart of Mesoamerican culture, agricultural biodiversity, farmers’ livelihoods and the right to food.

 

Throughout the history of this process, scientists, NGOs and the general public, for more than 15 years have raised these issues in various fora¹ with variable responses from the Mexican government (Peralta and Marielle 2010). A decision of this magnitude must be carefully considered. This requires a deliberative, inclusive and transparent risk appraisal process involving a wide group of actors. Unfortunately, the process of “public consultation”² (mandated by the aforementioned Biosafety Law) put forth by the Mexican government to date has been anything but these procedures. Not only is the length of public consultation allowed exceedingly short (20 days once the announcement has been made), but the lack of transparency of the process, given that the detailed outcome from the performed “experimental” and “pilot” GM maize releases have not been made public, has preempted any scientific scrutiny. This not only undermines the principles of independent scientific critique and verification that are at the core of sound science practice, but is also a missed opportunity to address biosafety issues more broadly that ensures the safety of any approved environmental release of a genetically modified organism into centers of origin and genetic diversity. Furthermore, the Mexican government has decided on a public consultation process that limits the scope of comments on approval to those that can be “scientifically and technically substantiated”³, thereby restricting those who can “legitimately” provide feedback and artificially framing the issue of approval or non-approval as if there were only scientific and technical concerns. This completely ignores equally valid and reasonable considerations of the social, economic, legal and ethical impacts of such a decision.

 

In this brief, we analyze the key environmental, health, legal, socioeconomic and agronomic/food security issues and their implications in the event that large-scale release of GM maize in México, its center of origin and diversity, is undertaken. We find that scientific justification and evidence of social, environmental or agricultural utility is lacking after over 16 years of planting GM crops in the United States and a few other countries (Gurian-Sherman 2009, 2012; Gurian-Sherman and Gurwick 2009; Benbrook 2012). But on the other hand, there is irrefutable scientific, social, environmental and cultural reasons to stop GM release at its center of origin and diversity (see also Commission for Environmental Cooperation 2004).

 

Our conclusion is that the most prudent action calls for greater foresight, by implementing a precautionary policy that ensures the conservation and sustainable use of México’s maize agricultural biodiversity. This requires establishing an official and effective moratorium on the cultivation of GM maize varieties, and embarking in a long-term research on the benefits, risks and opportunities provided by a range of agronomic practices for enhancing Mexican agriculture and improving the livelihoods of the Mexican rural communities. The latter should be evaluated in terms of their effectiveness to achieve a sufficient and sustainable maize production in México and deliberated inclusively by broader society. Such precautionary action has been taken recently in other countries harboring important agricultural biodiversity, specifically India for Bt eggplants, Peru for cultivation of GM crops and Bolivia for the dissemination of GM seeds.

 

 

The focal issue for the right to food and food security is making decisions today that will preserve this right for present and future generations. This means that agricultural policies must capacitate and not threaten the ability of farmers of today to provide a diversity of agricultural options for the farmers of tomorrow (Alvarez-Buylla et al., 2011). Central to this aim is agricultural biodiversity and México’s role in safeguarding maize agricultural biodiversity. Below we briefly analyze the potential implications of GM maize in México from the perspective of five issues: Environmental/biodiversity conservation, human and animal health, legal, socioeconomic and agronomic/food security. Many of these issues are intertwined, particularly in the instance of hybridization of GM maize varieties with non-GM varieties, a biological reality documented in México and observed even during the time the moratorium was in place and to this day (see references below). A number of complexities and uncertainties are discussed that merit further investigation and clarity concerning GM maize release in México, but enough evidence and data is at hand to justify precautionary action.

 

 

 

México, as the recognized center of origin and diversity of maize (Kato et al., 2009) maintains this agricultural biodiversity through seed exchange and selection by farmers, a vital activity for generating and maintaining the germplasm for maize breeders around the world in order to respond to a changing climate, new pest pressures, or consumer preferences (Alvarez-Buylla et al., 2011; Ureta et al. 2011). Evidence suggests that communities that maintain high levels of maize agricultural biodiversity are the best positioned for resilience against climatic changes (Bellon et al. 2011). The commercialization of GM maize in México is set to deeply disrupt the processes that underlie germplasm diversification and the livelihoods of peasants that produce over 70% of the maize used for human consumption in México.

 

The Mexican Biosafety Law contains a Special Protection Regime that was meant to safeguard the genetic diversity of local, wild and/or cultivated varieties of crop plants that have their center origin or diversity in México (LBOGM 2005). However, amendments to the biosafety regulations of this same law contradict it (LBOGM-Reglamento 2009) and did away with this provision, on the assumption that there were areas of México that did not require this special protection regime. However, in order to provide an apparently legal framework to be able to release GM maize varieties, the Mexican government has published, as mandated by the Biosafety Law, an agreement to establish the center of origin and diversity outside of which the GM plants could be planted. However, a scientific analysis undertaken by the leading biodiversity agency in México, CONABIO, found native corn diversity throughout the Mexican territory (Acevedo et al. 2011; CONABIO Official Report at: http://www.biodiversidad.gob.mx/genes/proyectoMaices.html), and together with the transgene flow data (Piñeyro et al., 2008), leads to the irrefutable conclusion that the entirety of the Mexican territory should be considered as the center of maize origin and diversity (Kato et al., 2009).

 

 

The agencies that oversee the implementation of the Mexican Biosafety Law maintain that GM maize production areas (primarily in the North of México) can be segregated from other areas of open- pollinated maize cultivation of “criollo” native varieties. However, a wealth of scientific evidence of gene flow in maize (Quist and Chapela 2001; Serratos et al., 2004; Serratos et al., 2007; Piñeyro et al. 2009a, b; Dyer et al. 2008, 2009; van Heerwaarden et al. 2012) and cotton (Wegier et al. 2011) in México demonstrates that on the contrary, coexistence is not possible. The incidence of “contamination” of the maize food supply in the USA with a variety of GM maize not approved for human consumption (know as “Starlink”) led to millions of dollars in losses for farmers, where a low level presence of the transgenes could still be detected in the food supply years after measures were taken to remove them (Marvier and Van Acker 2005). As Mexican maize production and consumption is much more extensive than in the USA, such gene flow would be much harder or even impossible to manage and revert. Given the persistence and uncertainties of the impact of transgene flow, this issue has further relevance to conservation, socioeconomic and legal implications, as discussed below.

 

 

The global experience with the two predominant GM traits; one conferring resistance to specific insect pests and the other providing tolerance to herbicide applications, are leading to the generation of resistant pests and weeds. This has the secondary environmental effect of the need to spray other herbicides and pesticides to face the problem, leading to the same cycle of resistance experienced with antibiotics in the medical field (Benbrook 2012).

 

 

Several studies have documented unexpected negative effects on non-target organisms as reviewed by Alvarez-Buylla (2004). Such effects are likely to multiply in megadiverse regions as México.

 

 

In contrast to many industrialized countries where maize is used mainly for animal feed and for industrial processes, in México, maize is consumed with very little processing in large quantities (240- 300 g daily) and is the staple food (Ackerman et al. 2003). Great uncertainties concerning the possible long-term animal and human health effects of consuming GM crops and being exposed to associated agrochemicals become very relevant (Domingo 2007), specially because a growing number of scientific studies are suggesting harm in test animals (Mathews et al. 2005; López et al. 2012; Malatesta et al. 2002a, b; 2003; Seralini et al. 2012). These findings have recently set off a global public debate on the need for long-term, standardized testing to fully address the veracity of these findings.

 

In addition, many studies (Classen et al., 1990; Arnason et al., 1994; Serratos et al., 1993; Vázquez- Carrillo et al., 2011) showed that the nutritional quality and secondary metabolism products of genetically diverse germplasm and native maize varieties (i.e. protein, free sugars, oil and phenolic content) was higher and more diverse in comparison to the uniform genetic pedigrees of GM hybrids, and would thus likely provide for a healthier diet for the Mexican population and sources of natural defense products.

 

 

There are several lines of bio-reactor GM maize being produced and tested; ranging from ones intended for biofuels, to those used to derive pharmaceuticals or experimental chemicals (Ellstrand 2003). A large-scale commercial planting of GM lines increases the probabilities that such bio-reactor seeds escape to the Mexican maize production regions and food chains; this would deeply threaten food security in Mexico and elsewhere, as Mexican germplasm would be required.

 

 

Socioeconomic, legal and biodiversity issues interrelate at the nexus of intellectual property rights (IPRs) via patents on transgenes and plant variety protection (PVP) on the hybridized varieties.

 

 

IPRs on GM varieties have the potential to deeply affect the communal management of seed stocks and thus threaten the reproduction of open seed systems indispensable for the longterm survival of landrace diversity (Alvarez-Buylla et al., 2011). We have not yet examined the implications of Mexican patent and plant variety protection laws, but this is certainly an area that requires more investigation.

 

 

In our research, we attempted to trace family pedigrees of the varieties used by the applicants and adapted for the Mexican environment, through the Mexican government Registro de Variadades Vegetales⁴. We found that the information is not available to the public through online sources. In our view, there is still the open question on whether these GM varieties for which patents and PVP are being sought by these private companies utilize Mexican maize germplasm that was developed by Mexican farmers or research institutions in their local adaptation breeding programs from which the commerical seed is then produced. The implications of the privatization issue for food security should be investigated further.

 

 

As México seems to be replicating policies and market strategies towards GM crops already enacted in places like the United States, the experience from this and other countries adopting agricultural biotechnology is valuable for forecasting similar outcomes there. The global experience with strong IPRs on germplasm has facilitated the concentration of seed supplies and the best lands under a very small number of multinational corporations (Adi 2006; Sagar 2000; Howard 2009) resulted in lower competitiveness (Pinstrup-Andersen 1999) and may contribute to changes in seed pricing (Shi et al. 2009). México’s seed sector is already heavily dominated by some of these same companies seeking to introduce IPR-protected maize in México (Luna et al. 2012) and commericialization will likely intensify their market power. Similar narrowing of the maize seed market, particularly if modifications to existing IPR regimes take place, could be expected to occur in México.

 

 

The livelihoods of Mexican peasants, as well as the agroecologically and locally adapted alternatives for sustainable maize production in México would be deeply threatened by a massive commercial release of GM maize (Nadal 2003; Alvarez-Buylla et al, 2011). Furthermore, the GM varieties do not yield more than the non-GM hybrids already used in the North of México, where the GM varieties may be released, so dependencies on the large maize producers will not likely solve the deficit in maize production. The latter could be actually solved with non-GM technology (Turrent et al. 2012).

 

 

Based on our analysis above, we conclude that the large-scale release of GM maize in México that will follow commercial approval will deeply threaten the core of Mesoamerican culture, Mexican food sovereignty and overall social well being, as well as global food security. The release of GM maize varieties is likely to further exacerbate existing inequalities, externalize risks and adverse effects and endanger all-important seed exchange practices that maintain and augment agricultural biodiversity since millennia and pose a potential threat to maize genetic diversity through transgene accumulation in open-pollinated varieties maintained by peasants throughout México. The only prudent decision at this time is to reestablish the moratorium on the releases of GM maize varieties in all of México, since further evidence has confirmed that the decision taken by the Mexican government in 1999 was based on scientifically sound arguments and experiences were rightly established. Furthermore, measures should be put in place, as recommended by the Commission for Environmental Cooperation (2004) to avoid the entrance into the Mexican territory of viable GM maize seeds.

 

1 See http://www.unionccs.net

2 See the ”Formato de Consulta Pública”, accessed November 20, 2012

3 Ibid. ”Dicha opinión deberá estar sustentada TÉCNICA y CIENTIFICAMENTE [their emphasis]”

4 http://snics.sagarpa.gob.mx/dov/Paginas/default.aspx