The Use of GM Crops in Developing Countries
The precautionary approach continued
4.39 The precautionary approach is thus relevant to the effectiveness of conventional and ‘organic’ agriculture in developing countries. As we have noted (paragraphs 2.13-2.14), expansion into marginal lands is usually a source of increased average cost, reduced returns, and increased environmental hazards. Nonetheless, for want of other options, the expansion into marginal lands is widely practised throughout much of Africa. This leaves an unmistakable and undesirable farming footprint characterised by exhausted or overgrazed soils, and degraded forests and other areas of wildlife. Much of the current agricultural practice in the farming of cotton, bananas and soybeans requires the application of large amounts of pesticides and fungicides, with adverse consequences for the environment, and the health of farm workers (case studies 1, 6 and 7). Thus, questions about the use of GM crops need to be posed in the light of a realistic comparator system:
- How does the use of a GM crop compare to other alternatives?
- What are the risks of the non-GM approach, that would constitute the option of ‘doing nothing’?
- In what respect are the risks posed by the introduction of a GM crop greater or less than those of the alternative system?
- Does the comparator system involve a higher level of benefits than the alternative system?
It seems likely that GM crops could have an active role to play in the safeguarding of the environment, if they can grow under more demanding conditions imposed by water shortages, or poor soils.40 The precautionary approach should also be invoked in cases of biological control, where, for example, wasps, are deliberately imported from another continent to act as the natural enemy of a domestic pest (see paragraph 4.6). While these solutions can make valuable contributions to improving agriculture in developing countries, the alleged naturalness of the approach should not distract from careful analysis of possible impacts on the environment. Here, too, the potential for the irreversible alteration of ecosystems needs to be considered.41
4.40 Thirdly, to hold to the most conservative interpretation of the precautionary approach invokes the fallacy of thinking that the option of doing nothing is itself without risk. Yet, as we said in our 1999 Report (Chapter 4, see also paragraphs 2.9-2.13 above), food security and environmental conditions are actually deteriorating in many developing countries. This is not to say that we should be imprudent in the assessment of risks. It is to say, however, that restrictive interpretations of the precautionary approach, that imply a general prohibition on the use of GM technology, require very strong justification.
4.41 We therefore conclude that an adequate interpretation of the precautionary approach would require comparison of the risks of the status quo with those posed by possible paths of action. We use the term precautionary approach to indicate that it is not a single inflexible rule, as often implied when commentators refer to the ‘precautionary principle’, but a way of applying a set of interacting criteria to a given situation. Such assessments must be based on sound scientific data. This is consistent with a cautious attitude in the sense that rules and procedures need to be put in place to safeguard against any untoward effects and to mitigate their incidence should they occur. However, it recognises that there can be dangers in inaction, or alternative courses of action, as well as in the adoption of a particular innovation, dangers that are of particular importance when people are vulnerable and hungry. Thus, provided that technological expectations are met, it could well be argued that the use of Golden Rice can be justified by a reasonable application of the precautionary approach, if alternative approaches are less cost-effective and unable to achieve the aim of preventing VAD (see paragraphs 4.21-4.26).
4.42 It is also worth noting that the precautionary approach needs to be applied in ways that ensure broader policy aims are met. A useful contribution in this respect is the Communication from the European Commission on the Precautionary Principle, which recommends that measures based on the precautionary approach should be, among other things:
- proportional to the chosen level of protection;
- non-discriminatory in their application;
- consistent with similar measures already taken;
- based on an examination of the potential benefits and costs of action or lack of action (including, where appropriate and feasible, an economic cost/benefit analysis);
- subject to review, in the light of new scientific data; and
- capable of assigning responsibility for producing the scientific evidence necessary for a more comprehensive risk assessment.42
40 We have also pointed out that, in specific instances, GM crops can have the potential for improving biodiversity (paragraph 3.38) as increased numbers and varieties of spiders, beetles and other insects that are important food for a number of birds have been reported for Bt crops.
41 See also Chapter 3, footnote 14.
42 European Commission (2000) Communication from