TABIO calls for the proposed field trials of Monsanto’s genetically modified maize to be scrapped. See TABIO's objection to the application by COSTECH and Monsanto for the WEMA test in full here.
SUMMARY OF APPLICATION:
The Tanzania Commission for Science and Technology (COSTECH) has applied for field trials of MON87460 at the Makutupora Viticulture Research and Training Centre (VRTC), Dodoma (BD.29/ 202/01) dated 19th February 2016. The application is a resubmission of a new application as a follow up to the previous one that was submitted on 27th April 2010 (Letter Ref. Nr. CST.SC/266/534/2010).
This submission lays out our concerns with the application and supporting documents submitted by COSTECH for research on MON 87460.
1. Data pertaining to MON 87460 safety to human health and the environment is lacking in the application. Many of the safety claims are based on assumptions, are not in alignment with current peer-reviewed data and therefore remain unsubstantiated.
2. ‘Confidential Business Information’ (CBI) obstructs meaningful assessment. We were unable to conduct a meaningful and rigorous independent scientific assessment of the applications because important information was withheld relating to data on sequence information of the expression cassette, the flanking sequences, or evidence of genomic stability. Information on the phenotypes are non-existent, bar the claim that MON 87460 is ‘equivalent to conventional maize’. It is therefore impossible to rule out known or probable risks associated with artificial genetic modification. We recommend gaining access to the raw data for independent review. Data from previous trials in Uganda and Kenya should also be provided.
3. Failure to demonstrate safety – the dossiers submitted by COSTECH 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 Environment Management Act and the Cartagena Biosafety Protocol to which Tanzania is a Party, obliges the National Biosafety Focal Point to refuse to grant the approval being sought by COSTECH.
4. Failure to include any plans to assess safety of MON 87460, despite the claim that this is a main objective of the trial.
5. GM drought tolerant maize is an inappropriate technological fix to a systemic problem. GM crops are embedded within the “Green Revolution” approach while this model of 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 agro-ecological methods to ensure diversity and resilience to mitigate and adapt to climate change.
6. Previous trials for MON 87460 in other countries show the use of a variety of chemical pesticides. Putting farmers on a chemical treadmill will have negative impacts on farmer’s livelihoods, as well as their health and that of the environment as a whole.
7. Environmental Impact Assessment: Can the EIA’s still be valid after 4 years, as normally three years is the limit of validity. Is there not a conflict of interest if an employee of the applicant also carries out the EIA?
8. Only researchers from Tanzania (government entities) have submitted their CVs, but none from the developer of the genetic engineering technology i.e. Monsanto. Although Monsanto is a collaborator just like others but being the developer and owner of the csp transgene construct may need to be held liable if any negative impacts warrant legal actions.
In light of the raised concerns we urge the National Biosafety Focal Point (NBFP) not to approve the application for MON 87460 submitted by COSTECH (Application REF No BD.29/202/01. We trust the committee will fairly judge the application based on the raised concerns for the interest of Tanzanian community and environment at large. There is a wealth of information about the approved drought tolerant local varieties with good potentials which have not yet been fully utilized. Wise use of resources is essential by directing our efforts in promoting the uptake of already researched and approved drought tolerant varieties such as OPV and Hybrid varieties recently developed in Tanzania by CIMMYT and IITA e.g. Vumilia H1, TZM523, IF630 instead of introducing GMOs which might cause adverse effects (www.dtma.cimmyt.org).
The NBFP should take into consideration the on going GMO debate around the world which has so far resulted in its rejection in most European countries. Tanzania should not rush to adopt GMOs which have already been rejected in other countries.