SAFeAGE
The South African Freeze Alliance on Genetic Engineering

Thank you for the opportunity to engage with you on the issues of GMO's and put forward the concerns of the 3.6 million consumers we are mandated to represent.

Who is SAFeAGE?
SAFeAGE is a large network representing at least 4 million South African consumers. We have been in existence from 2002.

WHAT ARE WE CALLING FOR?
1. SAFeAGE is calling for mandatory and meaningful labelling of foods containing and/or derived from genetically modified techniques, and
2. the entrenchment of the necessary Identify Preservation Systems to track
GM produce from "farm to fork" in order to ensure effective monitoring, risk management, liability and redress.
3. We are further calling upon DEAT to entrench Environmental Impact Assessments for GM crops to become part of a mandatory process instead of leaving it to the discretion of the Executive Council of the GMO Act, as it now stands.

THE SAFETY OF THESE FOODS IS UNCERTAIN to Humans. Animals and the Environment.
It is our total business to inform people of the dangers of GMO's. For the sake of brevity we will mention a recent incident that happened in South Africa that speaks to the lack of safety of GMOs, and ask the committee to view the enclosed DVD entitled "The Future of Food" which touches into all of the safety aspects, to humans, to the environment and to animals. We have much more information upon request.
On the 18th of June the South African Advertising Standards Body (SAASB) ordered Monsanto to withdraw an advert placed in the You Magazine entitled "Is your food safe? Biotechnology ­the true facts." In the advert Monsanto claimed that "no negative reactions have ever been reported". Upon investigation by the SAASB, this claim to safety was found to be untrue. (See Annexure 1). This incident highlights the fact that the safety of these foods is highly questionable, and consumers have every right to decide whether or not they are willing to take the risk in eating them. Therefore they MUST be labelled.

Even though no long term studies on the effects of eating genetically modified foods have been carried out to date, a vast number of short term studies on animals give us reason to worry about allergies, stomach lesions, immune system problems and more - See Annexure II - Dangers of Genetically Modified Food for a list of peer reviewed studies, which is not exhaustive). We respectfully ask that you also visit the websites: www.seedsofdeceDtion.com and www.safeaqe.orq and www.i-sis.orq.uk and www,qmwatch.orq for more info.

LACK
OF MANDATORY LABELLING ON GM FOODS
Current
laws are inadequate to uphold consumers' rights
South African consumers feel that the current labelling laws under the Department of Health's Foodstuffs, Cosmetics and Disinfectants Act are not sufficient to protect them from potential and unknown risks or provide them the right to choose what they eat. The current labelling laws do not trigger a GM label when foods have been derived from genetically modified techniques. Rather, as in the US, the law is based on the premise that genetically modified foods are "substantially equivalent" to non-GM foods. This is a premise advanced by the biotech industry that has not been scientifically investigated or proven. Animal feed has also been excluded from labelling as well as animals fed with GM derived foodstuffs. We have no knowledge of the effects of eating such animals.

We also have to question why, when it comes to patenting and profit, industry claims that these foods are novel, but when it comes to safety testing, liability and labelling, they claim that these foods are exactly the same? Consumers feel that this is not good enough and are demanding that in the face of uncertainty, foods with a GM threshold of over 0.9% must be labelled. (This is in line with
EU standards).

There is NO other labellina leaislation. A clause was recently removed from the draft Consumer Protection Bill calling for GM foods to be labelled, because it was felt by some that the whole matter of GMO's should be dealt with by the GMO Act. The only problem is that the GMO Act is focused on promoting GMOs in accordance with the mandate of the DoA and the interests of the biotechnology industry. As stated in the July
17, 2007 publication AgBio View:

The South African Government generally supports biotechnology: transgenic varieties of cotton, com and soy are approved for commercial planting and account for approximately 92 % of South Africa's cotton, 44% of com, and 59% of soybeans.!

Because of this.
the GMO Act contains no reauirements for the labelina of GMO's and. in addition. the liability reaime in the Act imDoses liability for damaae resultina from GMO's on users. includina end-users such as farmers and consumers. Recently adopted amendments to the GMO Act (contained in the Genetically Modified Organisms Amendment Act [B43-2005]) do nothing to address these gaps. This makes it clear that the DoA has no intention of introducing labeling requirements in the GMO Act to protect consumers. In any event, relying on the DoA to protect consumers is misplaced, as its mandate and specific area of expertise is the promotion of farming, not the protection of consumers.

The Precautionary Principle is entrenched in NEMA as well as in the International Biosafety Protocol, to which South Africa is a signatory. The precautionary principle states that if there are reasonable scientific grounds for believing that a new process or product may not be safe, it should not be introduced until we have convincing evidence that the risks are small and are outweighed by the benefits. The precautionary principle hinges on concept of the burden of proof, meaning that it is incumbent on those introducing a new technology to prove it safe, and not for the rest of us to prove it harmful. 3.6 Million Consumers are saying that this has not been done to their satisfaction, for this reason we are calling for labelling to allow us to choose food we believe to be safe and wholesome.

Conclusion
The safety of eating genetically modified foods is not yet scientifically established, we have
not monitored the effects of these on our health to date - that is impossible without labelling.
We are a consumer organisation and come to you representing FOUR MILLION consumers who have mandated us to demand from Government the right to choose what they eat, especially in the face of weak regulations in South Africa. Consumers are calling for meaningful labelling of foods derived from GM, the necessary Identity Preservation Systems to be enforced and Environmental Impact Assessments for GMOs, which make the process of decision making transparent and participatory, to be clearly devised and enforced.
We look forward to a personal presentation to the Portfolio Committee.


IDENTITY PRESERVATION SYSTEMS - by SABS. 2007
Although consumers have called for the labelling of GM foods and foods derived from GM processes because they feel it their right to choose, the food service industry and food retailers have consistently refused to label GM foods domestically because South African labelling legislation is weak.

However, identity preservation and labelling is already carried out for foreign export to comply with the demands of their customer base. The grain industry has already set up their own voluntary Identity Preservation Systems in order to cater for the strict European market as well as other neighbouring countries such as Namibia and Botswana and other SADC nations that require strict labelling or GM free products. If this is possible for the export market, it is certainly possible for domestic consumers, who have the same concerns.

The South African Bureau of Standards has developed 3 IP systems and adopted 2 ISO methods to trace and segregate foods derived from GMO's. Once IP Systems are in place and crops are tracked from farm to fork, labelling GMO's will be no more costly than the labels we currently find on any other food. The following standards are in place to track genetically modified organisms and derived products, but are not yet being enforced.

SABS facilitated the production of 3 standards on genetically modified foods and has adopted 2 ISO methods, namely:

1) SANS 10385-1, Requirements for the implementation of an identity preservation system (IP system) Part 1: IP production, storage, handling and transportation of non-genetically modified unprocessed agricultural products.
2) SANS 10385-2, Requirements for the implementation of an identity preservation system (IP system) Part 2: IP system for the processing and manufacturing industry.

3) SANS 10385-3, Requirements for the implementation of an identity preservation
                 system (IP system) part 3: sampling and testing protocols.

4) SANS 21571/150 21571: Foodstuffs-Method of analysis for the detection of
                 genetically modified organisms and derived products
- Nucleic acid extraction

5) SANS 21572/150 21572: Foodstuffs-Method of analysis for the detection of
                 genetically modified organisms and derived products - Protein based method.