This is a replay of how GM technology took root in the country 12 years ago.

In 2001, reports were rife of the widespread use of Bt cotton, the GM cottonseed, in Gujarat where thousands of farmers had started illegal cultivation before the regulators could approve its commercial use. Following a campaign by the industry and leading media organisations, Bt cotton was cleared without some essential safeguards. Regulators did little to check how Bt cotton was being grown, whether the mandatory refugia or buffer zones were being maintained to prevent the contamination of non-Bt fields that would also help to slow down the resistance to Bt.

In 2013, history is repeating itself as herbicide-tolerant GM cotton known as Roundup Ready Flex  (RRF) spreads illegally in at least three states. Roundup Ready Flex, first reported to be in use in Gujarat last season, has since spread to Punjab and Maharashtra although the regulator, the Genetic Engineering Appraisal Committee, has not cleared the technology. This is being field-tested by Monsanto’s Indian partner, the Maharashtra Hybrid Seeds Company better known as Mahyco.

Mahyco, incidentally, was the first Indian company to get approval for the commercial release of Bt cotton that was marketed as Bollgard in 2002.

Farmers’ organisations in Maharashtra, particularly those in Vidarbha, have become alarmed by the spread of the illegal Roundup Ready Flex. The region is notorious for the huge numbers of suicides by primarily cotton farmers in the past 15 years and farmers’ lobbies have been blaming the use of GM technology or Bt cotton as it is known for the spate of suicides. Glyphosate kills only the weeds and leaves the crop, reducing labour for farmers.  However, a significant concern with the heavy use of glyphosate is that it leads to the growth of superweeds that are resistant to glyphosate.

A recent report from Manitoba, Canada, says more than one million acres (404,686 hectares, one acre equals 0.4 ha) of Canadian farmland have glyphosate-resistant weeds growing on them. This estimate is based on a survey of 2,028 farmers, conducted by Stratus Agri-Marketing Inc. This is an extremely high figure which has been disputed but in the US, the biggest user of GM, pesticide use has gone up dramatically due GM herbicide-resistant weeds, warns Doug Gurian-Sherman of the Union of Concerned Scientists. “Millions of acres of glyphosate-resistant weeds are causing real harm, such as increased tillage that increases soil erosion,” he points out.

In India, the spread of Roundup Ready GM cotton is matter of serious concern since GEAC had called for additional tests by Mahyco. Kishore Tiwari of the Vidarbha Jan Andolan Samiti (VJAS), a farmers’ advocacy group that is fighting to safeguard the sustainability of agriculture in drought-prone Vidarbha,  says herbicide-tolerant Bt cotton is being openly sold at Rs1,500/ per packet of RRF (450 gm) “which is highly objectionable because RRF is yet to receive approval”.

GEAC sources say Mahyco has been asked to provide detailed data on the use of RRF and its impact on the environment and approval for its commercial release is some way off.

http://www.acbio.org.za/activist/index.php?m=u&f=dsp&petitionID=3

MODERNISING AFRICAN AGRICULTURE: WHO BENEFITS?

African agriculture is in need of support and investment. Many initiatives are flowing from the North, including the G8′s “New Alliance for Food Security and Nutrition in Africa” and the Alliance for a Green Revolution in Africa (AGRA). These initiatives are framed in terms of the African Union’s Comprehensive African Agricultural Development Programme (CAADP). This gives them a cover of legitimacy.

But what is driving these investments, and who is set to benefit from them?

The current wave of investment emerges on the back of the gathering global crisis with financial, economic, food, energy and ecological dimensions. Africa is seen as underperforming and in control of valuable resources that capital seeks for profitable purposes. The World Bank and others tell us Africa has an abundance of available fertile land, and that Africa’s production structure is inefficient, based as it is on many small farms producing mainly for themselves and their neighbourhoodsi.

Africa is seen as a possible new frontier to make profits, with an eye on land, food and biofuels in particular. The recent investment wave must be understood in the context of consolidation of a global food regimeiidominated by large corporations in input supply (seed and agrochemicals) especially, but also increasingly in processing, storage, trading and distribution.

G8 and AGRA: a new wave of colonialism

Opening markets and creating space for multinationals to secure profits lie at the heart of the G8 and AGRA interventions. Both initiatives are built on the basis of public-private partnerships (PPPs) with the large multinational seed, fertiliser and agrochemical companies setting the agenda, and states and institutions (like the G8, World Bank and others) and philanthropic institutions (like AGRA and others) establishing the institutional and infrastructural mechanisms to realise this agenda.

Multinational corporations like Yara, Monsanto, Syngenta, Cargill and many others want secure markets for their products in Africa. In the first place, security means protection of their private ownership of knowledge in the form of intellectual property (IP) protection. Across Africa, so-called ‘harmonisation’ of laws and policies are underway to align African laws and systems with the interests of these multinationals.

Harmonisation of trade laws means opening borders across the continent to free trade. But this is a skewed free trade, one that favours the ‘formal sector’ of goods and services that have gone through approval and registration processes. Farmers and other producers of goods and services who cannot afford to enter the official approval system are marginalised and trading of their products is rendered illegal.

Private ownership of knowledge and material resources (for example, seed and genetic materials) means the flow of royalties out of Africa into the hands of multinational corporations. In some countries where laws protecting the interests of corporations are well established – for example in South Africa – multinationals have entirely occupied domestic seed and agrochemical sectors with profits flowing out of the country. The same is happening for agricultural services, trade, manufacturing and even selling of food.

The private companies are not acting on their own. They are using investment-friendly government policies and plans to advance their agenda.

CAADP and regional investment policies: facilitating ‘orderly’ processes of colonialism

There are many well-meaning organisations and individuals who view CAADP as an African-based investment plan. But Africa is not isolated from the world. CAADP emerged at the height of neo-liberalism globally in the early 2000s. African governments were mired in the consequences of decades of structural adjustment that saw the net outflow of financial and other resources from Africa to the rest of the world. The New Economic Partnership for Africa’s Development (NEPAD) was an initiative by selected African governments to integrate Africa into global flows of capital. The expectation was that profit-generating investment, and creating the conditions for protection of this investment, were Africa’s chance to catch up with the rest.

African governments, desperate for some financial relief, are willing to make whatever changes are necessary to bring capital into their countries. The multinationals are setting the terms: harmonisation, free trade and protection of private IP or no investment. It is therefore of little use calling for CAADP to be placed at the centre of investment plans. CAADP itself is a compromised instrument, calling for the very policies and programmes favoured by the multinationals.

Food security and corporate-driven investment in Africa

Harmonisation, free trade, and the creation of institutions and infrastructure to facilitate multinational penetration into Africa are presented as the answer to food insecurity on the continent. Multinational corporations, African states, states outside Africa, philanthropic institutions, multilateral institutions such as the World Bank and even some non-government organisations are all part of this agenda. Surely so many organisations and people cannot be wrong?

The logic is that of the Green Revolution: introduce yield- and sales-enhancing technologies and systems, provide credit for producers to access these technologies, and anticipate increasing returns from sales to cover the increasing cost of inputs. Expand access to markets globally and regionally to absorb increased production.

This model can benefit some, as Green Revolutions in Asia and to a lesser extent in Latin America have shown. However, it also has negative social and ecological side effects. Green Revolution technologies benefit relatively few farmers, often at the expense of the majority. These technologies produce concentration of land ownership, increasing economies of scale (production has to be at a large scale to get into and stay in markets), and a declining number of food producing households in a context of limited other livelihood options.

Ecological concerns about Green Revolution technologies are rising to the top of the global agenda, especially loss of biodiversity when commercial hybrids and GM seed dominate (especially maize as a staple crop in Africa, and the introduction of soya as the basis of biofuels and commercial intercropping approaches), soil degradation and water pollution caused by excessive use of manufactured chemicals in synthetic fertilisers, and water shortages caused by wasteful water use in irrigation.

The Green Revolution produces uneven benefits, favouring farmers with financial resources of their own, with access to more land, and with some formal education. The majority of resource poor farmers are excluded from public support for agriculture, with infrastructure and institutional frameworks designed for the minority to benefit.

Currently African food security rests fundamentally on small-scale and localised production. The majority of the African population continue to rely on agriculture as an important, if not the main, source of income and livelihoods. In most sub-Saharan African countries, agriculture is the primary economic activity for between 50% and 90% of the populationiii. Even though there is growing urbanisation, the majority will continue to rely on agriculture for their livelihoods for decades to come. The rural population continues to grow in absolute terms even while the urban population grows as a proportion of the total population.

We know that all of these people will not benefit from these new investments. Seen as more inefficient than those producers who are in a position to adopt the new technologies, many will be forced out of agriculture to become passive consumers. Instead of building the broad base of producers, G8 and AGRA investments, supported by African government policies and resources, will narrow the base of producers.

The practical results of the recent surge in investment in African agriculture expose the empty rhetoric of African food security. Blatant land grabs are well known across the continent. Mega projects such as the ProSavanna project in northern Mozambique are displacing farmers from their lands and imposing large-scale production structures for export. Favourable investment terms (for example tax free zones and laws on repatriation of profits) undermine even the questionable benefits increased foreign exchange brings. Meanwhile actual farmers are separated from the land and the only realistic option for a livelihood. African governments and their investment "partners" enable and implement these projects.

Alternatives

First and foremost, differentiated strategies are required, so that local and informal markets, proven low-input and ecologically sustainable agricultural techniques including intercropping, on-farm compost production, mixed farming systems (livestock, crops and trees), on-farm biofuel production and use, and intermediate processing and storage technologies are recognised and vigorously supported. The emphasis here is on individual and household food security first, with trade arising from surpluses beyond this. The International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD) provides detailed and scientifically sound proposals in this regard.

Open access technologies are an essential principle, especially seed, where all recent technological advances are based on 10,000 years of collective experimentation and sharing. No-one and no corporations should be allowed to privatise the results of ongoing research. Companies can sell their new varieties, but once sold, they re-enter the common pool that anyone should be able to use and improve on at will.

Green Revolution technological development leads to an ever-increasing gap between conception and execution, that is between the knowledge that goes into producing a new seed variety and those who use the seed. An alternative, based on open source technologies, is a far closer working relationship between decentralised technicians and producers to define the research and development agenda (what traits are farmers looking for in specific locations, what crops are priorities for further development etc). Plant breeders are still able to make profits by selling new varieties to those who want to buy fresh seed, especially commercial farmers. But if farmers choose to reuse and adapt seed once they have bought it, that must be their right.

We therefore call on the G8, AGRA, CAADP and other similar institutions to:

*Acknowledge variation amongst farmers and commit to providing appropriate, dedicated support to all food producers rather than only a thin commercial layer;
*Abandon efforts to assert private ownership of germplasm, agricultural techniques and knowledge and to accept that these all emerge from a common pool
*Invest in and facilitate open source technological development together with farmers;
*Invest in ecological agriculture following the IAASTD proposals;
*Development finance to be based on grants and public programmes not for profit;
*Ensure smallholder women and men farmers are at the centre of any strategy for increasing investment in this sector. There should be recognition of the ongoing broad consultation of the *Committee on World Food Security (CFS) on Responsible Agricultural Investments (RAI). This process was the result of a decision of the CFS in 2011 following their rejection of the World Bank blueprint for Principles on Responsible Agricultural Investment in 2010.

For more information and to sign on: http://www.acbio.org.za/activist/index.php?m=u&f=dsp&petitionID=3

Networks:

Alliance for Food Sovereignty in Africa (AFSA), comprising of the following members: African Biodiversity network (ABN), Coalition for the Protection of African Genetic Heritage (COPAGEN), Comparing and Supporting Endogenous Development (COMPAS) Africa, Friends of the Earth- Africa, Indigenous Peoples of Africa Coordinating Committee (IPACC), Participatory Ecological Land Use Management (PELUM) Association, Eastern and Southern African Small Scale Farmers‟ Forum (ESAFF), La Via Campesina Africa, FAHAMU, World Neighbours, Network of Farmers’ and Agricultural Producers’ Organizations of West Africa (ROPPA), Community Knowledge Systems (CKS) and Plate forme Sous Régionale des Organisations Paysannes d’Afrique Centrale (PROPAC).

Tanzania Biodiversity Alliance comprising of: ACRA, ActionAid International Tanzania; African Biodiversity Network; African Centre for Biodiversity (South Africa) Bioland; BioRe; BioSustain; Community Water & Environmental Association; (COWEA); CVM/APA (Comunità Volontari per il Mondo / AIDS partnership with Africa); Envirocare; ESAFF; MVIWATA;PELUM; Sustainable Agriculture Tanzania; Swissaid; ANCERT; Tanzania Organic Agriculture Movement and Tushiriki. Alliance for Agro-Ecology and Biodiversity, Zambia; People’s Dialogue; Rural Women’s Assembly

Organisations:

African Centre for Biosafety
Biowatch South Africa
Surplus People Project
JINUKUN, Benin
FoodMattersZimbabwe
Women and Resources, East and Southern Africa
Kasisi Agricultural Training Cetnre, Zambia
Trust for Community Training and Outreach, South Africa
Inades Formation

i World Bank 2009 “Awakening Africa’s sleeping giant: Prospects for commercial agriculture in Africa’s Guinea Savannah zone and beyond”, World Bank Agriculture and Rural Development Unit, Africa Regional Office

ii McMichael, P. 2009 “A food regime genealogy”, Journal of Peasant Studies, 36: 1, pp.139-169

iii World Bank, “World Databank”, http://databank.worldbank.org/data/home.aspx

Moreover, the weight of evidence they rest upon is either not appropriate for the testing of new dsRNAs in food, or simply is an absence of evidence because of an absence of testing. FSANZ has the power in its legislation, it has the option under international food safety guidelines, and it has a responsibility to the people of Australia and New Zealand to ask for evidence of no detectable adverse effects from new dsRNAs in specific GMOs.

The purpose of risk assessment is to identify risk and then mitigate it before harm arises. FSANZ seems to be suggesting that they cannot ask for these risks to be investigated because they are awaiting scientific evidence that someone has already been harmed. We say: get the evidence of safety; don’t wait for harm.

* FSANZ claims that we underestimate “the strengths of the GM food safety assessment to detect possible unintended effects” that may be caused by dsRNA. This is wrong. What we do know is that FSANZ does not require animal feeding studies of any kind. In the approvals that we reviewed, it had never even required tests for detecting dsRNA in the blood of animals, much less required tests that would reliably detect unintended harmful effects from dsRNA. FSANZ does not monitor for effects on people after approval or specify any particular monitoring be done by the developing companies. FSANZ needs to do more than just say its processes work; it needs to be forthcoming on what evidence it relies on to show that all these new dsRNA molecules are no threat to humans.

* FSANZ makes a number of factual errors and logical non-sequiturs in its response. For example, FSANZ says that there is no scientific basis for positing that novel dsRNAs in food would cause an effect on people.

Contrary to what FSANZ asserts, there is scientific basis for suggesting that small dsRNAs present in some GM foods may pose a greater risk than those already naturally abundant in conventional foods. The effects of dsRNA in food are shown through the development of dsRNAs intended to be toxic to animals and are the basis of new pesticides. Animal toxicity is often used as evidence for potential toxicity to humans.

If there were no scientific basis for assuming that novel dsRNAs could have profound effects on human beings, then why by FSANZ’s own admission have there been so many attempts by the pharmaceutical industry to try and cause these effects? Surely these pharmaceutical researchers think it not just plausible, but probable and so do their stockholders.

On this point, FSANZ also cites evidence of a physiological effect of a drug based on dsRNA applied to skin. Food, in the form of flour or liquids, also touches human skin and can be breathed in, leading to inhalation exposure. FSANZ never addresses these risk pathways.

Furthermore, because drug developers may frequently fail does not mean nature will fail to deliver a potentially harmful dsRNA present in food. People also failed initially to build flying machines based on flapping bird wings. But birds nevertheless still managed to fly. And eventually airplanes were invented.

* FSANZ says that we failed to account for natural dsRNA already in food. This is wrong.
RNA molecules are in the food we eat, but to extrapolate from the safe use of food with naturally occurring forms to those that are engineered and unique to new kinds of food is wrong. Proteins of all kinds are also in the food we eat but new proteins are evaluated for the potential to be toxic or allergenic in food. These dsRNA molecules can participate in fundamental biological reactions in human cells and so must be tested to be determined safe.

* FSANZ claims that we rely on only one paper. This is wrong. Our research was split into “food safety assessment” and “environmental safety assessment” because these are often done differently, respond to different sources of international guidance and oversight, and by different regulators. Only part of our paper was therefore on food. We drew on many different sources to evaluate the evidence that dsRNAs may be taken up by humans through food (orally, breathed in, absorbed). Two recent papers, one from an academic research laboratory and the other from Monsanto, which has commercial interests in dsRNA, both confirm detecting dsRNAs of plant origin in mammals(Zhang et al., 2012b) and both mammals and people (Zhang et al., 2012a).

Combined, these papers confirm that dsRNAs can be taken up through food. The paper by Monsanto attempts to argue that many prior detections may be due to contamination, but it never shows that to be the case except in its own studies. Moreover, it never refutes the study by the academic laboratory. We discuss this at length in our research but unfortunately FSANZ seems to have overlooked this discussion.

FSANZ has mis-mashed disparate studies of different kinds, with different endpoints, unrelated testing approaches and which use different kinds of delivery to produce doubt about whether safety testing is needed. Invoking a series of failures to cause a physiological effect in people using different kinds of dsRNAs found naturally in food or which were generated in laboratories for other purposes is a broad stroke approach to risk assessment that is inappropriate for concluding the safety of new dsRNAs in food.

Meanwhile, it has not offered empirical evidence of safety. This is neither true to case-by-case risk assessment nor is it substantial reassurance that new dsRNAs are safe in the food products that FSANZ has approved.

In contrast, what we have shown in our research is that FSANZ has made a series of historical assumptions that in retrospect have proven incorrect. These assumptions were not its only choices because not everyone made them even at that time. Thus FSANZ could have made other choices then and now.

We acknowledge that there exist different scientific opinions on how to conduct risk assessments on GM foods and on other products that might contain novel dsRNAs. We anticipate that over time our recommendations will be improved upon. This will be the outcome of implementing actual testing and advancements in science.

However, at this time there is almost no experience with novel dsRNAs in food or other products and no monitoring of effects in the people who have eaten them. There has been little or no specific testing data published in the peer-reviewed literature coming from studies that would be designed to demonstrate the safety of novel dsRNAs on a case-by-case basis. In our research, we found no such specific testing in the cases we examined, including those that got FSANZ approval. The science exists to do the testing; it just hasn’t been required.

It makes sense to agree to what tests are appropriate, and to conduct them while such products are rare rather than wait until dsRNAs are in many consumer products.

Given all this, we suggest that it would be much more credible for FSANZ to restart this conversation from the vantage point of having experience with actual testing of novel dsRNAs on a case-by-case basis, and then move later to a discussion of whether more or fewer tests are warranted.

Let’s use scientific evidence to assure that the new dsRNAs in these foods are safe and prove us wrong about the need to test. We would love to be proved wrong.


Heinemann, J. A., Agapito-Tenfen, S. Z. and Carman, J. A. (2013). A comparative evaluation of the regulation of GM crops or products containing dsRNA and suggested improvements to risk assessments. Environ Int 55, 43-55.
Zhang, L., Hou, D., Chen, X., Li, D., Zhu, L., Zhang, Y., Li, J., Bian, Z., Liang, X., Cai, X., et al. (2012a). Exogenous plant MIR168a specifically targets mammalian LDLRAP1: evidence of cross-kingdom regulation by microRNA. Cell Res 22, 107-126.
Zhang, Y., Wiggins, E., Lawrence, C., Petrick, J., Ivashuta, S. and Heck, G. (2012b). Analysis of plant-derived miRNAs in animal small RNA datasets. BMC Genomics 13.