- Temba Nolutshungu, The Standard (Hong Kong), Feb. 8, 2006 http://www.thestandard.com.hk/

The World Trade Organization was expected to rule Tuesday against European Union barriers to GM foods. But this will not help millions of starving Africans get cheap and reliable crops: EU regulation-creep will keep them firmly in their place.

Zambia has just reconfirmed its ban on famine-relief containing GM food. Uganda and Kenya are wavering. More than 12 million people are starving in Africa right now. GM food would not solve malnutrition and starvation by itself, but it would certainly help.

But even South Africa, with bumper harvests of genetically modified crops, is threatened by irrational fears about them, even though they provide food and income for hundreds of millions of rich and poor alike. Activists there are calling for tight new legislation to restrict GM crops, citing the precautionary principle – a legal concept promoted by the EU and the UN.

At first sight, the precautionary principle looks reasonable. Have we not all since childhood been warned to look before you leap or, if in doubt, don't? Those who have followed the advice will no doubt at times have avoided danger, loss and even injury. On the other hand, if they followed the precautionary advice to avoid all risk, they would have missed a lot of opportunities and might even have come to grief.

The UN's Cartagena Protocol on Biosafety imposes restrictions on trade in GMOs and has been incorporated into a proposed Genetically Modified Organisms Bill in South Africa.

The protocols' stated intention is the conservation of habitats in developing nations, which sounds admirable. However, its reference to the precautionary approach contained in Principle 15 of the Rio Declaration on Environment and Development must give us pause.

The objective of the protocol is to contribute to ensuring an adequate level of protection in the field of the safe transfer, handling and use of living modified organisms resulting from modern biotechnology that may have adverse effects on the conservation and sustainable use of biological diversity. It also takes into account risks to human health, specifically focusing on trans- boundary movements. The problem here may have adverse effects.

The precautionary principle requires action to avoid a risk even when there's no evidence of any risk: it demands that technology should not be used unless, and until, it has been shown to be absolutely safe, reversing the usual burden of proof.

New technologies are assumed to be harmful until they have been proven safe to an impossible standard.

Dr Elizabeth Whelan, president of the American Council on Science and Health, says the precautionary principle always assumes worst-case scenarios, distracts consumers and policy-makers alike from the known and proven threats to human health while assuming no risk from the proposed regulations themselves: the precautionary principle overlooks the possibility that real public health risks can be associated with expending resources on eliminating miniscule hypothetical risks.

When the Zambian government turned away GM maize intended for its starving people because of a theoretical health risk, it created a real risk and turned a disaster into a tragedy. Denied the food, people died of starvation. But that same type of GM maize has been consumed by Americans and Canadians for more than a decade.

Applied to agriculture and food biotechnology, the precautionary principle ignores the very real existing risks of hunger, starvation and malnutrition that can be reduced or eliminated by the new products.

Applied decades ago to innovations such as polio vaccines and antibiotics, the precautionary principle would have cited occasional serious side effects at the expense of millions of lives lost to infectious diseases. Applied today to penicillin and aspirin (or peanuts and potatoes), to which some people are allergic, it would deny their use to others who are not allergic.

It's worth repeating that no one has yet detected any allergy, harm or risk to humans, animals or the environment from commercialized GM crops. Farmers use GM seeds because they're more efficient, giving higher yields and costing less in pesticides. Consumers use them because they're indistinguishable from any other crop and cheaper too.

By acceding to the Cartagena Protocol, African governments, including my own in South Africa, have risked deterring biotechnology companies from carrying out research in their countries or making their products available to their citizens.

Major potential investments that could provide jobs and reduce poverty in Africa are at risk. Without such investments, African scientists may leave the continent to research and produce elsewhere.

The precautionary principle requires that we take action to avoid a risk even when there's little or no scientific evidence of its existence, magnitude or potential impact. In that case, consider the risk of applying the precautionary principle. How do we know what harm it will do in blocking agricultural development? Can we be absolutely sure that rejecting biotechnology will not cause future poverty, hunger and malnutrition in Africa? We cannot be sure and nor can the opponents of the use of biotechnology. Applying the precautionary principle to itself, we must therefore avoid the risks attendant on not using biotechnology.

In a continent that desperately needs growth, food, jobs and exports, innovation is exactly what we need.

The United States, Canada and Argentina have the muscle to bring cases to the World Trade Organization, but African countries are still vulnerable to EU trade barriers and to Western activists supported by the aid industry, all opposed to free trade and GM products - just the tools we need to boost exports and fight famine.

For Africans, this really is a question of life or death.

--- Temba Nolutshungu is a director of the Free Market Foundation, South Africa

Comments on World Development Report 2008 by Prof Ingo Potrykus

In September 2007, the World Bank published its World Development Report 2008: Agriculture for Development [1] which "seeks to assess where, when, and how agriculture can be an effective instrument for economic development, especially development that favours the poor". In response to a consultation on the report, Professor Ingo Potrykus, one of the inventors of Golden Rice technology, submitted the following comments:

"I am retired a full professor of plant sciences from the Swiss Federal Institute of Technology, and I spent my scientific career and that of my research team developing and using genetic engineering technology to contribute to food security of the poor in developing countries. Our best known case is Golden Rice, developed to provide provitamin A to rice-dependent populations to reduce vitamin A-deficiency, which is responsible for about 6,000 deaths per day. Since my retirement in 1999, I have, as chairman of the Humanitarian Golden Rice Board and Network, focussed on delivering Golden Rice free of charge and limitations to rice farmers in the major rice-dependent countries. Please bear this background in mind when reading my comments.

I am glad to see that the report understands that there are indeed potential benefits for the poor from GMOs. The key question is "Why the slow progress in transgenics?", but the three answers given [in the report] are not in agreement with my own experience.

It is true that there is not to much work on "pro-poor" traits and crops; however there are hundreds of colleagues in public institutions, both in developing countries and in the West, highly motivated to work on both the traits and the crops, if funding were available. It is wrong to expect this kind of work from the private sector; the public sector is not recognizing its responsibility.

It is also true that "perceived risks" are a major barrier and it is good to read that there is no scientific justification for this perception. Indeed, after 25 years of biosafety research and regulation there is a wealth of clear scientific evidence as well as a scientific consensus that there is no inherent and specific risk associated with the technology. If someone claims the contrary, either he or she does not know the scientific literature or is lying .But I agree that there is the perception of risk which has to be accepted as a psychological fact. It should be up to governments to inform their people about what is right and what is wrong. But all this is nevertheless not the major reason for the "slow progress".

Where I can not at all agree is the notion that "weak regulatory capacity" is a major cause. It is true that regulatory authorities may have a negative impact. However, not because of weak capacity, but because of the principle of "extreme precautionary regulation". People involved become frightened of making a mistake, leading to the psychological situation that it is better not to take any decision at all rather than one which could be criticised by the GMO opposition.

The overwhelming cause for the "slow progress" is, however, the system of "extreme precautionary regulation" established around the world. Lacking any scientific justification, this regulatory system prevents use of GMO technology for the benefit of the poor; everywhere it paralyzes public institutions, specifically those in developing countries.

In the specific case of Golden Rice, a humanitarian project developed in the public domain, supported by the private sector and with the proven capacity of saving in India alone up to 40,000 lives a year [2], we experienced a delay in the adoption so far of seven years, solely because of regulatory requirements. It is probably fair to say that GMO regulation, in the context of Golden Rice, is responsible for the loss of 7 x 40,000 lives in India and, of course, of many more in the other countries.

I am not aware of any hypothetical risk stemming from Golden Rice (or actual risk from any GMO) which would justify this loss of life. The cost of taking a single transgenic event through the regulatory process is about US$ 20 million. In summary: compared to introducing a new non-transgenic strain, one single transgenic event with a pro-poor trait and in a pro-poor crop costs about 10 additional years of work and US$ 20 million.

Golden Rice will be in the hands of farmers from 2012 onwards, i.e. 13 years after the scientific proof-of-concept had been established. No public institution and no scientist in the public domain can afford to spend 10 years of an academic career on a project with so small a chance of publication; no public granting institution is willing to invest such an amount of funds into product development and deregulation of one single event, even if proof-of-concept has been established and there is a potential of saving millions of lives.

Present regulations prevent the use of the technology by the public sector to benefit the poor, and that is why "progress of pro-poor transgenics" is so slow. There will be no progress unless our society reduces regulation to scientifically sound requirements.

Therefore, whoever wants to exploit the great potential of GMOs for the benefit of the poor should not argue for a strengthening of present regulation but request adjustment of regulation to our present state of knowledge, not to that of an ideology.

There is no doubt that many more potential benefits of GMO technology for the poor can be expected, quite distinct from benefits to industry, nor is there any doubt that this technology is at least as safe as any other agricultural intervention.

I very strongly recommend that WDR2008 maintains an emphasis on the importance of GMOs for development and argues for regulations which enable the exploitation of this technology for the benefit of the poor.

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