Genetically Modified Organisms: public 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.

- Department of Environmental Affairs and Tourism: Hearings on Genetically Modified Organisms
- National Department of Agriculture: Genetically Modified Organisms Act, 1997
- Biowatch South Africa: Presentation on GMO's to the Portfolio Committee, Environmental Affairs and Tourism
- AfricaBio: Biotechnology today and tomorrow
- A Call for a Five Year Freeze on Genetic Engineering and Patenting in Food and Farming in South Africa
- Genetically Modified Food - your right to know (Woolworths)
- Altieri, Miguel and Rosset, Peter: "Ten reasons why biotechnology will not ensure food security, protect the environment and reduce poverty in the developing world"
- The World Conservation Union - Statement: To Portfolio Committee on Environment on the issue of GMOs
- Submission by Ekogaia
- Institute of Science in Society: Open Letter from World Scientists to all Governments Concerning Genetically Modified Organisms (GMOs)
- International Life Sciences Institute: Food Biotechnology - An introduction

Before commencing the hearings the Committee heard from the Department of Environmental Affairs and Tourism (DEAT) regarding the upcoming amendment to the Marine Living Resources Act of 1988. The Amendment is to be to Section 86 which would extend the Minister's mandate by one year until 2001. The reason for this amendment is that the DEAT could not complete the development of program infrastructure in the original time period given.

Ms. Semple (DP) asked whether this would be a repeating process, the Department bringing amendments back every year when they could not finish in time.

The Department answered that it is three specific programs that need to be completed and it is possible that they will be finished before the end of the original time period, but are not willing to chance that this will not be the case and that the programs would have to be discontinued.

The first presentation was from Ms K Njobe, the Director of Biodiversity Management in the DEAT.

Ms Njobe began her presentation by examining the DEAT's role with respect to GMOs:

• "Appropriate policy, legislation
• White Paper on Conservation and Sustainable Use of South Africa's Biological Resources: "Regulate the transfer, handling, use and release of GMOs in order to minimize the potential risks to biodiversity and human health."
• NEMA law reform process to include Chapter on Biodiversity guided by White Paper
• Cooperation with other government departments (Genetically Modified Organisms Act (Act 15 of 1997)
• Administered by NDA
• Applies to field trials and commercial releases of GMOs
• Set procedures for risk assessment
• Executive Council to advise Minister of Agriculture
• DEAT is a member of Executive Council
• Participation in the Biosafety Protocol negotiations
• Negotiated under auspices of Convention on Biological Diversity
• DEAT responsible line function department for Convention, thus, Protocol negotiations
• DEAT responsible for ratification process."

Ms Njobe then went on to discuss the Cartagena Protocol on Biosafety, negotiated under the auspices of the Convention on Biological Diversity (South Africa a party since 1995). The agreement was concluded in January 2000 and is open for signature (SA has not yet signed) until June 2001. This agreement controls the "transboundary movement, transit, handling and use of all living modified organisms (LMO=GMO) that may have adverse effects on the conservation and sustainable use of biological diversity, taking into account human health" (excludes pharmaceuticals).

South Africa under the Protocol would have to:

• Appoint a national focal point to manage a clearing-house mechanism (information and communication tool).
• Appoint competent authority responsible for Advanced Information Agreements and risk assessments.
• Appropriate legislation to enforce provisions of Protocol.

Ms Verwoerd (ANC) asked why the process for ratification of the Biosafety Protocol has been moving so slowly, considering that South Africa has not yet signed and the deadline is June 2001.

Ms Chalmers (ANC) asked the DEAT how far the Department is along the process of ratification.

Ms Njobe responded that there was a problem initially in determining who was to be the lead agent (DEAT or the National Department of Agriculture) in the ratification process. DEAT has now taken the lead and consultations are now underway with both the government and other stakeholders and a workshop is upcoming (no date set).

Mr Van Niekerk (FA) asked whether the NDA will continue to monitor GMOs.

Ms Njobe answered that under the GMO Act of 1997 it is the NDA's responsibility to monitor GMOs.

Ms Semple (DP) inquired as to the chances that the Biodiversity Protocol will be ratified in time.

Ms Njobe responded that the consultation process is underway; following consultations cabinet will be briefed (this is usually fairly timely) and then the issue will be brought before Parliament.

The presentation by the NDA was given by Mr. Shadrack R. Moephuli, the Registrar of the GMO Act, 1997.

Mr Moephuli began his presentation with an overview of South Africa's agricultural constraints:

• "Many rural poor by-passed by green revolution technological advances.
• 13% arable land.
• Increasing population = greater demand for food.
• Rapidly growing urban areas, leads to higher per capita food grain requirements.
• Increasing damage to ecology leads to major changes in climate and sea level.
• No net change in fish production."

Mr Moephuli then went over the GMO Act of 1997. He noted that the Act, implemented on April 1^st, 2000, promotes responsible development, production and the use and application of GMOs. It "aims to protect the environment and human health through risk analysis (assessments, communication and management)" and
"regulates the import, export, production and development of GMOs". Mr Moephuli then went on to discuss the Bio-Safety Structures within the NDA. They include the Executive Council, the Registrar, the Advisory Committee, Inspectors, Appeals and Regulations.

The Executive Council: Comprised of six national government departments (NDA, DACST, DEAT, DH, DL, DTI) and whose objectives include advising the Minister and ensuring compliance to the law. The powers and duties of the council include assessments required by the registrar; issuing instructions to the registrar; and making recommendations to the Minister on the appointment of the AC.

The Registrar: Appointed by the Minister, this individual administers the Act through the following functions: issuing permits; appointing inspectors; ensuring appropriate measures to protect environment and health from hazards.

The Advisory Committee: This committee, comprised of a maximum of 10 individuals for less than five year periods, acts as a national advisory body on GMOs. The composition of the AC is supposed to be 8 experts from a variety of fields and 2 from the public sector. The AC is supposed to advise the Minister and the Executive Council on issues dealing with GMOs.

Inspectors: Appointed by the Registrar, these individuals have the responsibility of inspecting any activity/process/facility dealing with GMOs. They can request information regarding any GMO activity and seize any appliance, book, statement or document or take samples of material to provide proof of contravention.

Mr. Moephuli's notes showed that the principal genetically modified crops in South Africa are Soybean (4.39ha), Maize (4.14ha) and Cotton (122.53ha). Other crops include tomatoes, sugarcane, potatoes, apples and eucalyptus. The impact on small-holder farmers is indicated as the following:

• "1996 - 6 resource poor small-scale (1-20ha) farmers participated in a Monsanto field trial for GM cotton.
• 1998 - 405 resource poor small-scale farmers have cultivated GM cotton!"

According to the NDA presentation, biotechnology benefits the communal growers in the following ways:

• "Improved Bollworm efficiency
• Wind and rain - negative effect on efficacy.
• Even under optimum conditions - spraying not as efficient as Bt.
• Reduced use and reliance on broad spectrum insecticides
• Reduced environmental pollution.
• Pesticide runoff into bodies of water, rivers - pollution of drinking water.
• Reduced broad spectrum insecticide use promotes biological control of secondary pests.
• Increased Savings
• Spraying 1 ha. of cotton equals 20km walk.
• Difficult to locate good quality water for insecticide sprays.
• Less sprays required - reduced spraying costs.
• Improved Safety
• Reduced handling of hazardous chemicals.
• Reduction of pesticide containers often used to transport drinking water."

Ms Semple (DP) asked for a list of the members of the Advisory Committee and of the Executive Council as well as their backgrounds. As well, are there any illegal GMO activities going on in South Africa?

Mr Da Camara (DP) asked how many inspectors are employed by the NDA and where they are deployed.

Ms Verwoerd (ANC) asked Mr. Moephuli to complete his presentation as he had failed to cover the last couple of pages of his slides dealing with the benefits of GMOs (covered in minutes above). She also wished to know is the NDA is looking at organic farming as another way to increase yields and safety. In some of the research she has seen, Ms Verwoerd saw that organic methods often give higher yields than GMO or current methods.

Ms Chalmers (ANC) asked if risk assessments are dealt with in the regulations and what public participation there has been in this process. She also wanted to know if there was a role to play for civil society on the Advisory Committee or Executive Council.

Mr September (ANC) noted that he was concerned that the Executive Council (EC) was comprised of only government officials with no NGO representation. He also wanted to know how active the EC had been so far.

The NDA responded that the Department encourages organic farming or any other strategies that will increase crop yields. The NDA's role is to facilitate any method chosen by farmers. GMOs are only one tool in the biotechnology toolbox. As to why there are no NGOs on the EC, Mr Moephuli had no idea. NGOs are not included in the Act but public comments are solicited when an application is received by the Registrar.

Ms Verwoerd followed up by asking how many comments had been received.

Mr Moephuli said that it had been few. In terms of the activity of the EC, they have met four times in the past year. In the presentation the NDA stated that some confidentiality was needed. This confidentiality refers to the technology discussed in the application and the protection of new inventions by companies applying for permits.

Ms Verwoerd (ANC) asked where we are at the moment in terms of GMO crops - are we investigating, testing the effectiveness and safety of GMO crops or are we at the stage where we are assuming such and are now implementing. In terms of yields, is it not true that the world produces enough food for everyone, it is just not evenly distributed. Keeping this in mind, how much of this GMO trend is altruistic (providing the world with food) and how much is profit driven? And who is looking at the impacts on human health?

Mr Moephuli responded that the poor are reaping the benefits of GMOs as it enhances their capacity to produce high quality crops. For resource-poor farmers, GMOs are a health benefit as they reduce the need for dangerous herbicide and pesticide use. On the EC sits an official from the Department of Health whose role it is to ensure that the GMOs do not damage human health.

Ms Chalmers (ANC) commented that one of her problems with GMOs is that they produce one high yield crop but then the farmers have to continue purchasing the seeds, making them dependent on the multinationals that control the GMO industry.

The NDA responded that this trend is seen in traditional crops as well.

Mr September commented that the Committee is concerned about the reliance upon a single firm for the sale of GMO seeds. If there is a reliance that is built and the price increases then there will be a serious problem.

Mr Da Camara (DP) asked how far behind SA will become in the agricultural sector if they do not move towards GMOs.

Mr Moephuli answered that SA is one of the world leaders in GMOs, both in development and in legislation. SA is one of the few countries that has adequate legislation to monitor and regulate GMO development, production and distribution. On the other hand, SA is still producing less than 1% of the world's GMOs. The United States produces nearly 70% of GMOs worldwide. China is also increasing their development and production of GMOs.

Ms Nqodi (ANC) asked if the AC has any teeth.

The NDA responded that the AC has the capacity to advise the Minister and the Registrar.

The Chair, Ms Mahlangu (ANC) commented that she was worried that the Act has been in place for 3 years and it was only implemented this year. She was also concerned about the lack of public awareness and the need for a campaign to educate the population on GMOs.

Mr. Moephuli stated that a public awareness campaign is slated as a priority in next years Strategic Plan.

Mr Septmber (ANC) noted that plans in Departments often don't materialize as they are envisioned and therefore is it possible the illegal GMOs are entering SA - Can the NDA assure South Africans that they are protected?

The NDA replied that the Department has done everything in its power to prevent illegal GMOs from entering the country but as in any case no plan is 100% foolproof. Mr Moephuli did note that the chance of someone bringing illegal GMOs into SA has been significantly reduced in the past year.

Mr Van Niekerk (FA) asked if there is any evidence that GMOs are hazardous to the health of humans, animals or the environment.

The NDA responded that there has been no conclusive evidence that GMOs are hazardous to health.

Ms Verwoerd (ANC) followed up by asking that this may be the case, but is there any proof that GMOs are safe? Also, why are EIA's not compulsory for applications?

Mr Moorcroft (DP) asked if all the hype around GMOs is justifiable or it is a case of sensationalism by the media.

Mr Moephuli commented that this is the role of the AC, to ensure that there is no justification to allegations in the media. The NDA noted that there is a strong regulatory framework in place to protect the citizens of the country but that the benefits of GMOs for SA also needed to be emphasized. There are many benefits to using GMOs, especially for developing communities.

Mr Swardt (ACDP) stated that the documents he had read from the other organisations at the hearings seemed to indicate that there were significant scientific concerns with GMOs. Is this the case? He was also concerned with the legal framework, as the EIA principles articulated in NEMA are not adhered to.

Dr. Webster (AfricaBio) informed the committee that there is a lot of misinformation out there. The problem facing the GMO sector is the sensationalism that is attached to genetic engineering, however beneficial it may be. It is the government's responsibility to disseminate accurate information which will inform the public to both sides of the debate. In terms of SA's shelves, there have only been three applications approved by the Registrar - 2 cottons and maize. There are no fruit or vegetable GMOs on the shelves. The long-life tomato that has been getting so much attention is produced using normal farming procedures. The biosafety process has to be upheld to prevent the mixing of gene animals with food, but what has been done has been internationally recognized as being of value to developing countries.

Ms Roux (Habitat Council) asked if an amendment could be put into the GMO Act which would require public participation in the application process.

Mr Moephuli answered that having civil society on the EC could compromise the confidentiality requirements of the field. In terms of labeling, the NDA is working with the Department of Health to produce regulations on labeling.

Mr Van Niekerk (FA) made the statement that there are few foods which have not been modified over time. What is happening here is simply a speeding up of the process. What must be prevented though is the mixing of genes, which the legislative framework does. SA needs to use this technology to feed its population.

Ms Semple (DP) asked what happens when the hormones given to plants are eaten by animals and then eaten by humans. When you change one area, all other will be affected as well. This is why long term tests and caution is needed in this area.

The NDA responded that the Department does have protocol on testing, but with respect to long term testing, what products in use in our kitchen for example have been tested over as fifty year period? Not many.

The presentation was delivered by Ms Elfrieda Pschorn-Strauss (See Appendix 1).

Ms Justine Webster from AfricaBio gave the committee a brief presentation on GMOs.

"AfricaBio is a non-political, non-profit biotechnology association for food, feed and fibre, serving as a forum for informed debate on biotechnological issues in Africa." Their mission is "to promote the enhancement of food, feed and fibre through the safe use and responsible application of biotechnology and its products."

Her first comment was that biotechnology is just one tool that can be used to advance agriculture. She commented that all our existing foods are the result of genetic modification through selection and breeding. At present we are in the first generation of GM foods and the focus is on herbicide tolerance, insect resistance and disease resistance. The future of GM foods includes the desire to improve the nutrition, to remove allergens and toxins and to remove odours and flavours.

Ms Webster then moved on to discuss the environmental benefits of GMOs, which include:

• "Decrease pesticide use (US Department of Agriculture data)
• Renewed ecology around fields - targeted pesticides
• Soil, air and water renewal
• Conservation of natural resources - less land allocation to farming"

The farming benefits include:

• "Safer for all on and around farms
• Better yields on the same amount of land
• Better quality produce
• Less impact on the environment
• Less input cost (soya, enzymes)"

Ms Webster then discussed the focus of the plant biotechnology in SA. It is primarily aimed at controlling diseases and pests, more specifically insect and virus pests and fungal and bacterial diseases. She noted that the overall crop loss estimates due to pests and diseases is 35% worldwide and 40-50% in Africa. Other projects developing in SA include improving the storage properties of food, improving weed control, improving yield and quality of food, protecting natural resources and drought and salt tolerance. In terms of competitive issues, biotechnology is a tool needed to improve efficiency, quality and processes; reduce costs; and new niche markets.

Ms Webster concluded that it is important for the committee to put Africa's needs first. It is critical that the European vision not cloud the decisions concerning Africa. If a genetically modified product is beneficial and safe, we need to review its value to Africa and be able to use it if so desired.

SAFeAGE's presentation was given by Karen Kallmam. SAFeAge is asking for a five year freeze on genetic engineering and patenting in food and farming in South Africa. During the Freeze the following must be developed:

• A system enabling people to exercise their democratic rights to choose products free of GE ingredients and derivatives.
• A comprehensive review of government policy and legislation concerning GE.
• Public participation in decision-making.
• Independent assessment of GMOs social and economic impacts on farmers.
• A system to prevent genetic contamination of the environment.
• Independent assessment of the implications of patenting genetic resources.

According to Ms Kallman it is essential to "develop a public policy process which is open, transparent and includes civil society representation on the Advisory Committee to the Executive Council on GMOs."

Other issues brought forth by SAFeAge included their view that South Africa must become a signatory to the Cartagena Protocol to ensure a strong regulatory framework for the transport of GMOs.

"It is imperative that an immediate freeze on genetic engineering in food and farming is declared until we have assessed and understood the implications for consumers, farmers and the environment."

Mr Glenn Ashton began by commending the government on NEMA, declaring it to be a strong piece of legislation that will help protect and develop SA's natural resources well into the future. On the other hand the GMO act is fundamentally flawed and is biased to promote biotechnology. One of the problems with the Act is that liability is not pinned on the originator, thus absolving companies of responsibility for their products. The Green Party has concerns of extensive independent research into genetically engineered (GE) organisms. Since its inception the GMO Act has also been very difficult to implement. The EC is ineffective and the AC has made no attempt to bring in members of the public. Mr Ashton also questioned the ability of the Department to properly monitor GMO activity in SA.

The Green Party called for a suspension of all GMO licenses issued by the Registrar and a hold on any further licenses until more research can be done. The want to see a drafting of a new act which involves civil society. In the mean time GMOs should be looked at on a case by case basis.

According to Mr Ashton it is a myth that we need GMOs to produce more food. A World Bank Report identified the following problems as critical to developing Africa's food supply. They were:

• Care of soil
• Improving organic matter management
• Lack of phosphate in 90% of African soil

GE is not a magic bullet noted Mr Ashton. It is a high tech solution designed to garner maximum profits for those wholly unaffected by the problem. In the words of Gandhi 'the world provides enough for everyone's need, but not enough for everyone's greed.'

Woolworths
Dr. Ferreira began by stating that Woolworths had begun their research because their customers were concerned. Woolworths wanted to know how they were going to provide their customers with a choice: if they do not want to purchase GE foods, then there will be that option. In order to do this WW has had to research all of their raw materials in order to properly label the products on their shelves.

If a GM raw material cannot be removed then it will be labeled clearly. After the investigation WW did find GM materials in some of their products. They are currently ¾ of the way finished their research and their conclusions so far indicate that they will end up with a few labeled GM products on their shelves, but not many.

Conclusion
The Chair, Ms G Mahlangu, summed up by saying that another meeting was needed to unpack these issues in more detail. As of right now the Committee does not know whether the glass is half full or half empty and they need to make informed decisions about such important issues. The Chair thanked all the organisations for coming and commented that it was imperative that their knowledge was brought to the Committee in the future to ensure a complete set of information.

The Chair wishes to hold another meeting in the new year and then table a report in Parliament from the Committee with recommendations. She thanked the presenters again for their preparation and commitment and asked them to join her in this process. The meeting was adjourned.

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BIOWATCH SOUTH AFRICA

PRESENTATION ON GMOs TO THE PORTFOLIO COMMITTEE_,
ENVIRONMENT AFFAIRS AND TOURISM

11 October 2000

Thank you for this opportunity to put forward the position Biowatch holds on genetically modified organisms and biosafety. Biowatch is an NGO dedicated to monitoring and researching the implementation of the Biodiversity Convention in South Africa. We are committed to promoting the conservation and fair and sustainable use of biodiversity and its contribution to local livelihoods, and are extremely concerned about the increasing private ownership of our biological resources and related knowledge. Genetic engineering raises for us fundamental environmental, health, ethical and human rights issues which form the basis of our support for a five year freeze on the use of the technology in field trials and commercial plantings in South Africa.

I was tempted to dress up today in my Green Activist clothes, carrying a torch and ready to burn fields of genetically engineered crops - as has been witnessed through Europe, the Americas and most recently Thailand and India. But instead I decided to don my ordinary rationale cloak - for increasingly this is an issue that is reaching out to each and every one of us - from the most moderate academics to the most extreme activists. This is not a bunny-hugging, emotional and Eurocentric issue. It concerns basic human rights - to food security; to healthcare; and to environmental sustainability. Such issues resonate in Africa - a continent which is being targeted by biotech companies anxious to find alternative markets for their rejected products and to recoup their heavy investments in genetic engineering.

South Africa is unashamedly seen as a springboard to enter Africa - and the marketing strategy that has been used is to depict genetic engineered crops as the answer to poverty and hunger. To ensure that their investment Is quickly recouped, companies slam a hefty technology fee on each bag of seed and have patented technology to genetically engineer sterile seeds so farmers are forced to buy seed from the company every year.
Madame Chair - you do not need to be a rocket scientist - or a biotechnologist for that matter to understand these issues and the threat they face to food security in Africa - where some 90% of food is produced by customary farming practices.

This is one of the reasons why we oppose genetic engineering as a solution for Africa and indeed South Africa. There are many more. Before I go into these reasons, I will first explain briefly which GE crops concern us at this moment in time.
Bt-maize and cotton are commercially planted in South Africa and has been ₉enetically engineered with the Bt gene (Bacillus Thuringiensis), a naturally occurring bacterium that acts as a pesticide. This enables the plant to emit Bt 24 hours a day, in the leaves, stalks and roots of the plant. Target insects die and the theory is that the farmer need to spray less pesticides. The next kind of GE crop to be planted is genetically engineered to be resistant to the Roundup Ready herbicide of Monsanto. In other words, when the farmer spray RR herbicide, all the weeds die, except for the RR plant.

Now, to return to our reasons of why we oppose GE, and I take these reasons from a recent open letter to all the governments of the world by the Institute of Science in Society and signed by 364 scientists worldwide. You each should have a copy of this in your folders. I will just mention some of these concerns.

Biodiversity: We believe genetic engineering should be considered an environmentally dangerous technology that is breaking down the barriers that have protected the integrity of species for millions of years. Far from having environmental benefits, GM crops are a major threat to biodiversity. St-resistant insect pests have evolved in response to the continuous presence of the toxins in GM plants throughout the growing season, and the US Environment Protection Agency is recommending farmers to plant up to 40% non-GM crops in order to create refugia for non-resistant insect pests. GM crops with Bt-toxins kill beneficial insects such as bees and lacewings, and pollen from St-maize is found to be lethal to monarch butterflies as well as swallowtails. Keep in mind that in South Africa, St crops are already widely distributed.

Then there is also the threat to agro-biodiversity where genetic engineering will allow farmers access to even less varieties of crops. Consider Argentina, where 90% of the soya is one kind of GE soya. Farmers have no choice and any diversity they might have had, is lost.

Health: The potential hazards of GMOs to human and animal health are now widely acknowledged. Particularly serious consequences are associated with the potential for gene transfer between species. These include the spread of antibiotic resistance marker genes that would render infectious diseases untreatable, the generation of new viruses and bacteria that cause diseases, and of particular concern to us in South Africa is the link this might have to TB. Scientists differ widely in their opinions on the health risks of GMOs
and in listening to these arguments, I have to conclude that we simply do not know enough. It is on this basis that the British Medical Association, in their interim report (published May, 1999), called for an indefinite moratorium on the releases of GMOs pending further research.

Ethical: We have very serious ethical concerns about the patenting of life forms that is pushed by the biotech industry. Just as civilized societies have decided that there can be no ownership of human beings (slaves), we believe that there should be no ownership of genetic code, which should continue to be the shared common heritage of all.

Socio-economic: When I listen to those who say we must intensify and bioengineer agriculture to feed the world, I notice they are basing their arguments on 3 basic assumptions: 1. Hunger is caused by a lack of food, which is false, as hunger is caused amongst other factors by the unequal distribution of food and land. Even in the US people go hungry. 2. Intensive industrial agriculture can produce a lot more food. This is also false as it widely accepted that yields are stagnating and our resource base that is needed to sustain the word's population is being undermined by industrial agriculture. 3. And then, the TINA assumption: There is No Alternative.

Here I would like to tell you the story of Cuba. South Africa has a close relationship with Cuba - we now have lots of Cuban doctors here! Did you realise that 80% of Cuban farmers are organic farmers? That Cuba is becoming a model of self-sufficiency, sustainable agriculture and even urban agriculture, to the rest of the world? US sanctions prevented access to agrochemical products and as a result they had to find local solutions and will
now also have a huge market advantage. According to official figures, in 1999 organic urban agriculture produced 65% of Cuba's rice, 46% of the fresh vegetables, 38% of the non-citrus fruits, 13% of the roots, tubers, and plantains, and 6% of the eggs. Think what this can do for food security South Africa.

Madame Chair, in South Africa we are especially worried. We are the only country in Africa growing GMOs commercially and one of only a few countries worldwide. Most other countries have been much more cautious and did not buy into the fearmongering argument that they might miss the biotech train. They realise the power of this technology and that the only thing they might miss is access to world markets and sovereignty in their food supply. But here in South Africa, permits have been granted for about 175 trials for a wide range of crops; there has been 3 commercial releases and this year and the Dept. of Agriculture estimates that 250 OOOha of GE crops were grown.

In South Africa, as is the case elsewhere in the world, simple characteristics account for all the hectares of GM crops planted since 1997 The majority are engineered with St-toxins to kill insect pests and the latest release is genetically engineered to be tolerant to the companies' own brand of herbicide.

It is difficult to see how SA is to benefit from this. The only people seeming to benefit from genetic engineering in South Africa are the companies and researchers at universities and our parastatals who get funded by the companies and locked into secrecy agreements. No objective and independent research is being done on GMOs and agriculture as a whole is in a crisis as farmers have to depend on the agrochemical companies to advise them.

Recent research we have conducted in South Africa has made us especially alarmed. It has revealed not only that there have been virtually no comprehensive environmental assessments undertaken of any of the field trials or general releases, but also that there has been scant attention paid to the socio economic impacts of the technology. In fact, farmers planting Bt cotton in KwaZulu Natal are in general not aware they are doing so -despite their signing contracts with Monsanto that they can neither read nor understand.

Furthermore, no monitoring is taking place of who plants what, whether refugia are kept and why. We also have discovered that virtually no farmers are growing Bt maize. Why? Because the consumer markets require that maize be guaranteed GE-free - and no farmer is prepared to risk a premium price.

Madame Chair,
Thank you for listening to us - but before we end we have five simple requests and questions that we hope can be answered by yourselves and the Departments of Environmental Affairs and Tourism and Agriculture:

One. That a public policy process be initiated to engage all stakeholders in a national debate on modern biotechnology - or genetic engineering - and the risks and purported benefits to South Africa of this extremely new and untested technology.

Two. We are extremely concerned to hear that the national Department of
Environmental Affairs and Tourism wishes to absolve itself of responsibilities with respect to biosafety and pass on these responsibilities to the Dept. of Agriculture.
Madame Chair we find it completely unacceptable to have the Department of Agriculture being both a player and referee in this very risky game. We urge for the continued but strengthened involvement of DEAT in this vital issue.

Third. We want to know from you WHO is representing civil society interests in the Advisory Council and WHO sits on the rest of the Council.

Fourth. We request that a process be set in place to ensure signature of the Biosafety Protocol by South Africa when opened for signature once again in January in New York. In December some outstanding issues on the Biosafety Protocol will be discussed in Montpellier France and we urge you to ensure that we build on the continuity established by the DEAT, which was very ably managed by the head of the delegation and done with great consideration for the African Group as instructed by the Minister.

Fifth. A complete overhaul of the SMO Act - involving proper public participation and input - is critical if we are to manage genetic engineering responsibly in South Africa. It is well recognised that the existing GMO Act is fundamentally flawed. A group of prominent lawyers scrutinised the Act earlier this year and were unanimous in their criticism of the Act and its newly passed Regulations, and commented that the legislation showed "a cynical disregard for contemporary international and national environmental principles, as well as for the development imperatives of South Africa." A full review of the Act is available from Biowatch.
Finally Madame Chair, at a recent conference hosted by Africabio, an organisation whose stated aim is to ensure that unfair trade barriers on GMOs do not hamper the Biotech industry in this country, we had the opportunity to hear one of its members summarise their interpretation of the days' proceedings as follows: "leaders take people where they want to go. Great leaders take people not where they want to go but where they ought to go". Is this, we ask with heavy heart, the kind of democracy that South Africa has fought so long and hard for?

Thank you

CONTACT DETAILS:
Elfrieda Pschorn-Strauss