THIRD WORLD NETWORK BIOSAFETY INFORMATION SERVICE
Dear Friends and Colleagues
Overwhelming Opposition to Field Trials of GM Maize in South Africa
South Africa is in the grip of the worst drought experienced since 1992. The total maize crop for the year is estimated to deliver only 4.7 million tonnes of the average consumption quota of 9.6 million tonnes/year. Maize meal prices have increased by 20%. It is against this backdrop that Monsanto is seeking to expand the use of its genetically modified (GM) drought-tolerant maize in the country.
More than 25, 000 people, however, have signed a petition opposing Monsanto’s extended field trials, supporting objections submitted by the African Centre for Biodiversity (ACB) to South African GMO regulators. The trials are of three ‘stacked’ GM drought-tolerant maize hybrids: MON 87460 (drought tolerance) x MON 810 (insect resistance); MON 87460 x NK603 (glyphosate tolerance) x MON 89034 (insect resistance), and MON 87460 x MON 89034. The trials are to take place in several locations in the Western and Northern Capes, Free State and Mpumalanga.
The single herbicide-tolerant and insect-resistant traits were approved for commercial release in South Africa at different times starting in 1997. MON 810 was discontinued after the 2012 season due to the widespread development of pest resistance and replaced by MON 89034. Despite more than a decade of use, GM maize has not addressed food insecurity in the country; 46% of South African households suffer from hunger.
The ACB’s key objections are: (1) Confidential business information obstructs meaningful assessment; (2) GM drought-tolerant maize is an inappropriate technological fix to a systemic problem; (3) Best biosafety practices are being ignored; (4) Controversies regarding the already approved parental lines have not been taken into account for e.g. the failure of MON810 and the use of the glyphosate which has been categorised by WHO as a probable carcinogen to humans; (5) Questionable safety data presented by Monsanto; and (6) The dossiers submitted by Monsanto in the application for the trials did not provide sufficient evidence to demonstrate safety. Details of the key concerns are reproduced below.
With best wishes,
Third World Network
131 Jalan Macalister
10400 Penang
Malaysia
Website: https://biosafety-info.net/ and http://www.twn.my/
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ACB’S OBJECTION TO MONSANTO’S APPLICATION FOR AN EXTENSION PERMIT OF DROUGHT TOLERANT GM MAIZE HYBRIDS:
MON 87460 x MON 810
MON 87460 x NK603 x MON 89034
MON 87460 x MON 89034
by the African Centre for Biodiversity (ACB)
http://acbio.org.za/wp-content/uploads/2016/06/Obejection-to-Monsanto-field-trial-extensions-June-2016-ACB.pdf
SECTION 2: KEY CONCERNS WITH APPLICATIONS FOR STACKED TRIALS
This submission lays out our concerns with the safety dossiers submitted by Monsanto for an extension of field trials of MON 87460 x MON 810, MON 87460 x NK603 x MON 89034 and MON 87460 x MON 89034.
1. ‘Confidential business information’ obstructs meaningful assessment
The ACB was unable to conduct a meaningful and rigorous independent scientific assessment of the applications because important information was withheld relating to inter alia the location of the trial and the environmental conditions (including distance from nearest human settlements, weather, topographical, soil conditions; data on sequence information of the expression cassette, the flanking sequences, or evidence of genomic stability. Information on the phenotypes are nonexistent, bar the claim that the phenotype of all three varieties are ‘equivalent to conventional maize’, ‘except for the introduced traits’. It is therefore impossible to rule out known or probable risks associated with artificial genetic modification. We also note that tables on pesticide treatments appeared to have been ‘cut-and-pasted’ across all three of the safety dossiers, thus casting the rigour of the safety information provided in serious doubt.
2.GM drought tolerant maize is an inappropriate technological fix to a systemic problem
GM crops persist with “Green Revolution” technology while industrial agriculture has been identified as a major contributor to climate change. As we struggle through a prolonged drought, the appropriateness of an industrial farming system in the face of climate change needs to be urgently assessed with a view to transforming agricultural production to agroecological methods to ensure diversity and resilience to mitigate and adapt to climate change.
3.Best biosafety practice – case-by-case assessment – is being ignored.
The stacked events are not being assessed on their own merit, rather, the parental lines are considered in isolation. This approach is inadequate in terms of our GMO Act, as the new stack events must be assessed for combinatorial effects to ensure environmental, human and animal health safety.
4. Controversies also surround the already approved parental lines, which have not been taken into account. These include the following:
4.1 The approval for commercial release of Monsanto’s drought tolerant trait, MON87460, is currently under appeal. The ACB has appealed on a number of grounds, including that a single gene (cspB) is highly unlikely to confer efficacious drought tolerance while risking the introduction of yet another novel and controversial gene into our staple food chain. This represents no benefits while introducing new risk.
4.2 MON810 has been replaced by the stacked Bt event, MON89034, in South Africa due to the development of pest resistance and resultant product failure. Expert opinion predicts that MON89034 is likely to develop similar resistance.
4.3 NK603 confers tolerance to the herbicide glyphosate. This chemical is deeply controversial since the WHO International Association for Research into Cancer (IARC) categorised it as a Class 2A carcinogen in May 2015. The ACB also wrote to the Minister of Health as far back as 2012 asking him to launch an investigation into the toxicity of glyphosate and the lack of capacity for monitoring its use and impacts in South Africa, as well as asking for a review of risk assessment procedures to include chemicals associated with GMO crops. The South African public has since then called once again for similar actions and in 2016 almost 2000 people signed a “Glyphosate Must Fall” petition, which is attached hereto marked “B”.
5.Questionable safety data presented by Monsanto
It appears that Monsanto has simply copied and pasted tables regarding insecticide treatments across all 3 previous trial data reports, as identical treatments are reported for all. Bt was applied to crops that should have been expressing Bt toxins. Insecticide treatments were also identical to the field trial data for MON87460 x NK603, which unlike the other lines, does not express Bt toxins. Herbicide treatments, bar the additional use of glyphosate on the glyphosate tolerant line, were also identical. The rigorousness of these safety dossiers is therefore seriously brought into question.
6. Failure to demonstrate safety
The dossiers submitted by Monsanto in the application for these trials did not provide sufficient evidence to demonstrate safety. Our submission points to a number of areas of scientific uncertainty that pose serious risks and require further research. The Precautionary Principle enshrined in the GMO Act and the Biosafety Protocol to which SA is a Party, obliges the Executive Council to refuse to grant the extension permits being sought by Monsanto.