The Use of GM Crops in Developing Countries
Regulatory and ethical issues continued
5.26 Similar projects have recently been announced by the FAO, to the same ends.19 Whilst the commitment of any international organisation to the improvement of administrative capacity in developing countries is to be welcomed, duplication of effort among international organisations can be counter-productive. Administrative resources are scarce in developing countries and it is important to ensure that international development efforts are coordinated.
5.27 It is clear that regulation needs to be established primarily at the national level. However, diverse regulations, requiring that every new GM crop is assessed for possible risks to human health and the environment in each country, can cause problems. For most developing countries, it will be a major financial and logistical challenge to provide the capacity and resources to undertake such evaluations. The absence of appropriate testing facilities could delay the granting of approval for much needed improved crops. We therefore recommend that particular attention should be given to measures that will enable the sharing of methodologies and results. An example is environmental risk assessments for countries which have similar ecological environments. It should also be considered whether harmonised regional policies can be established, for example by the Southern African Development Community (SADC) and the Common Market for Eastern and Southern Africa (COMESA).20 In this context, we welcome the recent initiative by SADC to produce guidelines on food safety assessment and management of GM crops.21 We also recommend that developing countries should implement as far as possible standardised procedures for the assessment of environmental and health risks. Established international guidelines such as the Cartagena Protocol on Biosafety (see paragraphs 5.7-5.10) and the guidelines of the Codex Commission (see paragraphs 5.5-5.6) should be considered. Care must be taken to avoid an overly restrictive interpretation of the precautionary approach (see paragraphs 4.37-4.41 and 5.10).
5.28 The transfer of experience from advisory and regulatory bodies in developed countries to the developing world is urgently needed (see paragraphs 4.49-4.62 of our 1999 Report). Poor compliance of farmers with technical specifications, illegal planting of Bt cotton in India22 and the smuggling of GM soybean seeds from Argentina to Brazil are already raising concerns.23 By ensuring appropriate public awareness, and by insisting on transparent arrangements for overview and enforcement, costs and any risks associated with GM crops can be minimised (see paragraphs 5.30-5.36).
5.29 What kind of regulatory systems are appropriate for the enforcement of biosafety regulations in developing countries? It is again difficult to generalise. For example, in China and Ghana, very different conditions prevail with regard to the capacity for policy enforcement, the number of farmers, and the type of agriculture. In particular, the very large number of small-scale farmers in developing countries poses great challenges for enforcement.24 It seems unlikely that regulation can be achieved successfully by a compulsory ‘command-and-control’ approach. Such measures may be successful in developed countries, where licensing and monitoring is frequently a standard component of agricultural policy. However, in many developing countries it will be more likely that the intended effect of a particular policy will be achieved by incentives and well developed extension systems. An assessment of appropriate regulatory systems at the national level is beyond the scope of this Discussion Paper.
Footnotes19 Fresco L (2003) “Which Road Do We Take?” Harnessing Genetic Resources and Making Use of Life Sciences, a New Contract for Sustainable Agriculture, in EU Discussion Forum Towards Sustainable Agriculture for Developing Countries: Options from Life Sciences and Biotechnologies FAO, Brussels, 30-31 Jan 2003.
20 COMESA is a regional grouping of 20 countries of Eastern and Southern Africa with a population exceeding 380 million. It was established in 1994 to replace the Preferential Trade Area for Eastern and Southern Africa (PTA) which had been in existence since 1981. COMESA aims to function ‘as an organisation of free independent sovereign states which have agreed to co-operate in developing their natural and human resources for the good of all their people.’ SADC comprises 14 Southern African nations and has the general aims of achieving development and economic growth, alleviating poverty, enhancing the standard and quality of life of the people of Southern Africa and supporting the socially disadvantaged through regional integration.
21 Njoroge J (2002) Southern African nations to probe GM safety, SciDev.Net. Available: http://www.scidev.net/News/index.cfm?fuseaction=readnews&itemid=273&language=1. Accessed on: 2 June 2003; SADC (2003) Launching of the SADC Advisory Committee on Biotechnology and Biosafety. Available: http://www.sadc.int/index.php?lang=english&path=newscenter/mediareleases/&page=mr35_16042003. Accessed on: 20 May 2003.
22 Jayaraman KS (2002) Poor crop management plagues Bt cotton experiment in India, Nat Biotechnol 20: 1069, see Chapter 3, footnote 14.
23 Bonalume Neto R (1999) Smugglers aim to circumvent GM court ban in Brazil, Nature 402: 344–5.
24 It is estimated that there are about 817 million small-scale farmers in developing countries, see FAO (1988) The Impact of Development Strategies on the Rural Poor: Second Analysis of Country Experiences in the Implementation of the WCARRD Programme of Action (Rome: FAO).