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Date:

August 26, 2005

Subject:

Feared superweeds not so super after all; CROATIA PASSES LAW ON GMOS; ROLE OF PLANT GENE IN HEAT TOLERANCE STUDIED; EU Commission Response to ITSSD Precautionary Preference Study

 

Today in AgBioView from www.agbioworld.org: August 26, 2005

* GM crop or not
* Feared superweeds not so super after all
* CROATIA PASSES LAW ON GMOS
* RABOBANK SAYS HALF OF WORLD COTTON MAY SOON BE GM
* BIOTECH AND IPR IN DEVELOPING COUNTRIES
* ROLE OF PLANT GENE IN HEAT TOLERANCE STUDIED
* Gray or Green Revolution?
* Agro experts, farmers getting training on bio-tech crops
* No More Chicken Run
* EU Commission Response to ITSSD Precautionary Preference Study
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http://nation.ittefaq.com/artman/publish/article_21153.shtml

GM crop or not

- The New Nation, By Mostafa Kamal Majumder, Aug 24, 2005

Is biotechnology the only way for the world to feed its population which is expected to hit a 9 billion mark by the year 2020? The US embassy in Dhaka in association with the Bangladesh Agricultural Research Council (BARC) held a day-long conference in Dhaka on Wednesday primarily giving a positive answer to this question.

A number of US experts in biotechnology having wide experience in the use of molecular techniques for genetic modification of crops for increasing yields as well as improving their food value spoke unequivocally in its favour.

On the sidelines conference opponent of genetically modified crops circulated papers carrying messages like “Say no to GMOs”.

The debate on GMOs is global with the United States strongly promoting GM food and the whole of Europe opposing its consumption equally strongly. Countries like Bangladesh often cannot decide which argument of the debate to side with even though GM crops not certified by the national seed control committee are finding ways directly to farmers’ lands.

A number of GM vegetable species like tomato, pumpkin and cucumber are already being cultivated and marketed in Bangladesh. The Grameen-Monsanto deal of the late nineties to establish a laboratory for research in biotechnology in Dhaka had attracted strong criticism from both within Bangladesh and outside forcing Grameen Bank’s founder Dr. Muhammad Yunus to scrap their agreement. But there has neither been effective official surveillance, nor non-governmental watch-groups which could have prevented the influx of hybrid and GM seeds not certified by the authorities concerned.

What makes opponents so strongly critical of GM food is the artificial introduction of ‘good’ genes and removal of ‘bad’ ones from crop plants with a view to making those insect resistant and give higher yield of crops of ‘better’ food value. New genes introduced are not only plant genes but also bacterial genes. A state of the art technology indeed - a byproduct of the green revolution.

Opponents are apprehensive of the likely mutagenic effects of artificial modification of natural plants and their crops. Proponents of GM food say on the other hand that plants, so to say crops, modified naturally through processes like cross-pollination over the centuries and GMOs are nothing new.

Dr. Nina V Ferdoroff of the Pennsylvania State University. USA, says that the argument of GM crops leading to loss of biodiversity does not hold good, because planned agriculture through selection of preferred species itself can also be accused of causing this loss.

T Clint Nesbitt of the US Department of Agriculture told newsmen on the other hand that the opposition to GM crops in Europe might be due to some extent to the fact that people in the continent generally do not have high degree of respect for their regulatory bodies and their decisions. In the US the situation is the reverse, the people respect decisions of regulatory authorities. This explanation is too simplistic because people in almost the whole of Europe are obedient and law abiding citizens of their respective countries.

If the European fear of adverse health effects of GM food is turned aside, as is done in the US, only logically explainable argument against such food thought of by US experts is the urge of Europeans to protect their own crops and farm communities by continuing farm subsidies. But subsidies are given also in the US.

Fear raised by proponents of application of indigenous knowledge and protection of local crop varieties as safeguards for the future that introduction of GM crops would cause further loss of indigenous varieties and increase dependence on multinationals, is not accepted by US experts. They say, traditional varieties can well be, and actually are, stored in gene banks and may be brought back to use when felt necessary. They also say that there has been no proven adverse effects of the intake of GM foods.

Scientists in Bangladesh are divided and belong to both sides of the debate. The government is finalising a national biotechnology policy and establishing a national institute on the discipline. Knowledgeable circles believe that before giving a seal of approval to GMOs the government should promote a national debate on it and deal with the issue with informed knowledge.
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http://www.newscientist.com/channel/opinion/mg18725145.800

Feared superweeds not so super after all

- New Scientist, Andy Coghlan, 27 August 2005

Blaming the emergence of herbicide-resistant weeds on GM crops misses the real problem, says Andy Coghlan

THE debate over genetically modified crops has been one of extremes. In Europe, fears that such plants would wreak environmental havoc triggered an almost hysterical backlash against their use. In the US, the debate was so muted one might be forgiven for not noticing that the country has become the world's GM breadbasket.

The latest study into GM crops, however, may give some Americans pause. Research published by Krishna Reddy of the US Department of Agriculture's Southern Weed Science Research Unit in Stoneville, Missouri, details the emergence of 15 weed species resistant to glyphosate, the weedkiller used in conjunction with the first and most abundantly grown generation of GM crops (Outlooks on Pest Management, DOI: 10.1564/16aug11).

GM sceptics have long warned that GM crops will encourage "superweeds" that are almost impossible to kill. This could happen either through the transfer of glyphosate-resistance genes from GM crop plants to weeds, or ...

Full article at:

http://www.newscientist.com/channel/opinion/mg18725145.800
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http://www.isaaa.org/kc/CBTNews/2005_Issues/Aug/CBT_Aug_26.htm#3

CROATIA PASSES LAW ON GMOS

- Crop Biotech Update, August 26, 2005

The Croatian Government passed a new law on Genetically Modified Organisms (GMO) that replaced the “biotechnology-regulating provisions” of the Law on Protection of Nature. The United States Department of Agriculture reports that the new law stipulates that the Ministry of Health will become the lead ministry for all biotech issues.

Previously, the Law on Protection of Nature and the Food Law including future sub-laws regulated the importation, transshipment, production, usage, and sale of products of agricultural biotech products (including all food, feed and seed). The GMO Law removed the previous provisions regarding biotechnology in the Law on Protection of Nature and replaced them as a new separate piece of legislation. The Food Law remains as the main law for regulating biotech food and feed.

See the USDA report in

http://www.fas.usda.gov/gainfiles/200506/146130111.doc.
*******************************

RABOBANK SAYS HALF OF WORLD COTTON MAY SOON BE GM

- Crop Biotech Update, August 26, 2005

Genetically modified (GM) cotton planted worldwide may account for more than 50 percent by 2006-07 from the present 35 percent. This was the projection of a cotton industry report released by the Netherlands-based Rabobank Groep. Bloomberg News quotes Rabobank as saying that “The expansion of GM production, particularly in regions which already operate under a fairly low-cost production system, will have long-term implications upon the marginal cost of production and, subsequently, prices.”

Rabobank noted that farmers in India and Brazil have started to use the technology and thus will contribute to yield increase. Brazil, the world's fifth-largest cotton-grower, is projected to become the largest growth market for biotech cotton. It noted that the inherent cost savings was expected to encourage the use of GM seed and thus strengthen the South American country’s cotton exports.
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BIOTECH AND IPR IN DEVELOPING COUNTRIES

- Crop Biotech Update, August 26, 2005

Developing countries need to cope with the fast developing intellectual property rights (IPR) regime. They should ensure that their legislation and procedures emphasize the enforcement of IPR through administrative action and through the existing civil justice system. In like manner, efforts must be made to exploit the maximum possible benefits in terms of cost reduction and administrative efficiency from existing regional and international cooperation mechanism, through various bilateral agreements in IPR. These were some of the recommendations raised by K.K. Tripathi of India’s Department of Biotechnology under the Ministry of Science and Technology in an article “Biotechnology and IPR regime: In the context of India and development countries.”

Tripathi also called for developing countries to encourage policy research and analysis on IP subjects especially those concerning protection of plant varieties, traditional knowledge, folklore, and technology transfer.

Read the full paper in the Vol. 7, No. 2 issue of Asian Biotechnology and Development Review or email Tripathi at kkt@dbt.nic.in.
**************************************

ROLE OF PLANT GENE IN HEAT TOLERANCE STUDIED

The greatest problems of plants in tropical climates are drought and high temperature stress. The latter inhibits plant photosynthesis, disabling nutrient accumulation and stunting plant growth. Plants have been known to also accumulate certain chemical compounds under salinity, drought, and temperature stress.

One of these chemicals, glycinebetaine (GB), is the subject of a recent study, where Xinghong Yang and colleagues from the Chinese Academy of Sciences Plant Physiology report that the "Genetic Engineering of the Biosynthesis of Glycinebetaine Enhances Photosynthesis against High Temperature Stress in Transgenic Tobacco Plants." Their findings appear in the latest issue of Plant Physiology.

Scientists introduced the betaine aldehyde dehydrogenase (BADH) gene from spinach into tobacco cells, allowing the transgenic cells to produce GB. The plants started accumulating GB, and resulted in their increased tolerance to high temperature stress during growth. Plants, to some extent, were also able to assimilate carbon dioxide better than their wild-type counterparts at temperatures as high as 45°C, showing that their photosynthetic pathway had not been greatly damaged by the heat stress.

The findings suggest a new function of GB in plants, in that it can protect photosynthesis against high temperatures. They likewise lend strength to the option of introducing BADH into plant cells in order to effect heat tolerance, a process which bypasses biosafety concerns, since the gene can come from a fellow plant.

Plant Physiology subscribers can access the full article at

http://www.plantphysiol.org/cgi/reprint/138/4/2299.

Other readers can access the abstract at http://www.plantphysiol.org/cgi/content/abstract/
138/4/2299.
*************************************

http://allafrica.com/stories/200508240416.html

Gray or Green Revolution?

- Ghanaian Chronicle (Accra), August 24, 2005, by Sing Ling Jabbah

UN chief and Millennium Excellence award recipient, Kofi Annan says Africa needs a "Green Revolution" to get us out of poverty and into economic prosperity. I agree. But we need more than a green revolution. We need a "Gray revolution" first - a complete overhaul in the way we think otherwise we would only produce more food to feed others.

What is generally called the Green Revolution began in Mexico in 1944 and spread like an epidemic across the world. In India and Pakistan, it is credited with saving over one billion people from starvation. The use of genetic engineering in agriculture to create genetically modified foods is viewed by some as the natural continuation of the Green Revolution. Ghana's "Operation Feed Yourself" programme in the 1970s was our humble attempt at replicating the Green Revolution.

The goal of the Green Revolution, the process of technological development of agricultural techniques, was to increase the efficiency of agricultural processes so that the productivity of the crops was increased, and to help developing countries face the food needs of their growing populations. Mexico went from having to import half its wheat to self-sufficiency by 1956 and, by 1964, to exporting half a million tons of wheat. Norman Borlaug who was instrumental in the scheme of things won the 1970 Nobel Peace Prize for his efforts.

But the first truly green revolution, inappropriately called the Industrial Revolution, occurred between the mid 18th and mid 19th century. This was a period in which fundamental changes occurred in agriculture, textile and metal manufacture, transportation, economic policies and the social structure in England. Agriculture at that time, was at the centre of the English way of life both as source of subsistence of the population and as an indispensable source of raw materials for the textile industry. The common practice in early agriculture to allow the land to lie fallow after it had been exhausted through cultivation, was replaced with the cultivation of clover and other legumes that helped restore soil fertility. The improved yields also increased the amount of food available to sustain livestock through the winter. Other advances in agriculture included the use of sturdier farm implements fashioned from metal, a great improvement on farming implements of the time, most of which were made entirely out of wood. Horse power replaced oxen power. These changes in the methods of production in agriculture made it possible to feed all the people that were attracted to the industrial centers as factory workers. By providing enough food to sustain an adequate work force, England was preparing the way for expansion of the economy and industry.

Ghana's "Operation Feed Yourself" programme in the 1970s for which the late General Ignatius Kutu Acheampong is well known, was perhaps the Ghanaian version of the Green revolution. Mass production of food was the direct result of the establishment of State farms across the country but this success was poorly managed - Cocoa for instance was locked up in the hinterlands, unable to reach centres to be prepared for export. There was no vigorous effort to set up agro-based industries as a necessary follow up. Instead, we continued operating within the same neocolonialist economic paradigm of producing and exporting raw materials and importing finished goods. Soon, 'Kalabule,' or Kutu's version of today's pervasive corruption, dissipated the rest of the gains from Operation Feed Yourself.

Since then, we have groped in the dark with programmes initiated, assuming importance only in name and reduced to a few symposia and workshops with no practical action to change the fundamental structure of the economy. The "Youth in Agriculture" programme is one shameful example of how we excel in crafting programmes and spend the rest of the time just talking about them. The other is the PSI or the Presidential 'Spurious' Initiatives (PSI) which aims at "diversifying agriculture, increasing exports and generating employment" but not necessarily to increase food crop production, much less increase the nutritional intake of Ghanaians.

The Day of Scientific Renaissance of Africa was celebrated on June 30 this year under the theme: "Science and Technology in Ghana's Agriculture and celebration Industrial Growth" was reduced, as it has been since 1988, to a talk shop. The 21st National Farmers Day is being launched today under the theme, "Agricultural Production and Productivity, Key to Growth and Poverty Reduction." But that is all there is to it. Tomorrow, you and I will go hungry with no prospects of breaking the cycle. No one ever solved a problem just by talking. We have to put our shoulder to the wheel or what the French call "Se jetter dans l'entreprise".

Eradicating extreme poverty and hunger means increasing agricultural production and food consumption, and improving nutritional content of diets. To accelerate the pace of reducing hunger in Africa, we must make the gray matter in our skulls work for us. An increase in agricultural production will not guarantee reduction in hunger if our mindset is geared towards consuming the refuse of western civilization or is it 'evilization'? Mass produced nutritious local foods could be sold cheaply only to buy rotten meat and 'polished' rice coming from some white man's country that JAK's policies endorse as the way forward.

Ghanaians are not only underfed but also malnourished. We need more quality and nutritious food and not just more of any kind ofjunk food. Without being able to do some of the basic things for the mass of the people, we literally remove the planks on which patriotism is built. And if we cannot even feed ourselves, we have no justification for asking for permanent seats at the UN. We need a "Gray Revolution" - a complete and irreversible change in our reasoning.
*****************************************

http://www.bangladesh-web.com/news/view.php?hidDate=2005-08-26&hidType=BAE&hidRecord=0000000000000000058248

Agro experts, farmers getting training on bio-tech crops

- Bangladesh Web, August 26 2005

A large number of agriculture experts as well as farmers of the country are undergoing training to ensure the safety of new biotech food and the environment, reports BSS.

The training programmes are eing organized by the South Asian Bio- safety Programme (SABP) with the financial assistance of United State Agency for International Development (USAID).

SABP Country Coordinator Professor Imdadul Hoque on Thursday told BSS that so far more than 100 agri-experts were given training under the SABP from February last on awareness building and experimental field trials of Genetically Modified (GM) crops in Bangladesh.

“Our goal is to develop a sustainable network of trained government and non-government experts, who can examine any GM food before entering the market on individual safety, allergenicity, toxicity, nutrition and eco-friendliness,” he added.

A regional training programme on technique of handling the bio-tech crop will be held in Bogra next month where at least 60 Agriculture workers including farmers, upazila officers and students will participate.

“If we can reduce the amount of product loss affected by pesticide as well as produce the saline and drought tolerance crop by biotechnology then there will not be any food crisis for our next generations,” Dr. Hoque observed.

The SABP programme, which started in February 2005, aims to impart training to nearly 500 experts in the sector over the next three years.

The ministry of Environment and Forest has already developed a bio safety guideline for Bangladesh.

Ministry of Agriculture has approved a variety of Golden Rice including BR-29 as well as Bt-eggplant and late-blight- resistant transonic potato for trial at Bangladesh Rice Research Institute(BRRI) and at Bangladesh Agriculture Research Institute (BARI) under confinement conditions.
************************************

No More Chicken Run

- Wall Street Journal, By ALEX AVERY and DENNIS AVERY, August 26, 2005

Factory farming is healthier: for animals and people. That's the take-home message as Dutch health authorities this week ordered free-range poultry farmers to bring inside their five million outdoor birds. There the birds will be less vulnerable to catching or spreading the deadly avian flu virus that's made its way from Southeast Asia to the doorstep of European Russia in recent weeks.

German health authorities are considering their own ban on outdoor birds, over the objections of their country's organic, free-range poultry farmers. Thomas Dosch, head of Bioland, Germany's largest organic organization, said that "exceptions are needed from the order," such as allowing birds to use open-air pens covered by netting. Unfortunately, such netting will not protect the flocks from the wild-bird droppings that spread the disease. Organic farmers are obviously more concerned with their market premiums than public and poultry health.

Southeast Asia has been the origin of all pandemic flu strains and the less deadly annual flu varieties. The new H5N1 flu strain has killed more than 60 people in Asia and destroyed Asia's poultry industry. Why? Free-range farming.

Asia is full of the small, "mixed" farms promoted by organic farmers, environmentalists and animal-welfare activists. Alternative-farming Web sites give endless testimony on the benefits of allowing free-range birds to live their "inner chicken," so to speak.

It's all a load of manure. The best reason to raise poultry and animals indoors is to prevent massive epidemics that would kill millions of people and farm creatures. The same flu virus that infects people also infects pigs, poultry, wild birds -- even whales. The more species swap viruses with each other and people, the greater the potential for a deadly, highly infectious human strain to evolve.

Global Asian influenza pandemics in 1957 and '68 each killed roughly a million people. The 1918 Spanish Flu pandemic killed 20 million to 40 million. An equivalent death toll for today would be over 100 million, which the World Health Organization says is possible if avian flu evolves into a strain capable of being passed between humans.

Vaccinating people helps, but it's hardly a solution. Vaccines always lag behind viruses because they take months and millions of fertilized chicken eggs to prepare. Meanwhile, the flu viruses continue to change, compromising the vaccines.

That's why experts now focus on the root of the problem: traditional Asian farms raising the whole song load of Old McDonald's animals in the same open barnyard. For months, the WHO has been lobbying Asian governments to gear up for a radical shift of pig and poultry farms to the modern confinement model so hated by the activists.

Activists claim it's unethical to keep animals indoors. But last November, an EU panel found that banning cages for laying hens would significantly reduce animal welfare due to disease, parasites and cannibalism. Our family's dozen free-range chickens prefer the protection of the barn rafters to the hawk hazards outside. Besides, it is hardly animal welfare when flu outbreaks require the euthanasia of tens of millions of birds or pigs.

To lower the risk of a deadly pandemic, Asian authorities are instituting several immediate steps: First, they have shut down the traditional live poultry markets in the major cities -- a brewing virus-swapping cauldron. Second, they are encouraging farmers to confine their animals and to separate them by species. Ducks are being emphasized because of their interaction with wild waterfowl and because they are silent carriers of the flu virus.

Thailand has approved a vaccination program to inoculate free-range chickens, ducks and other birds. But Thai officials see no need to inoculate poultry raised in confinement because these farms have already applied extensive preventive measures and the lack of interaction with wild birds.

Raising poultry in confinement also makes our food directly safer. Research in the U.K. and Denmark has shown that free-range poultry is three times more likely to be contaminated by salmonella and campylobacter bacteria -- two of the most common illness-causing, food-borne bacteria. Why? They're exposed to far more of these pathogens from wild bird droppings.

For years we've been told by so-called "experts" that free-range is better and healthier. Now we know better. If Old McDonald were alive today, he'd raise his chickens indoors.

Dennis Avery is director of the Hudson Institute's Center for Global Food Issues in Virginia. Alex Avery is director of research at the Center.
**************************************

EU Commission Response to ITSSD Precautionary Preference Study

Mon, Aug 22, 2005 3:36 am

Many thanks, Lawrence, for your considered reply. You ask for my "thoughtful response". Difficult, as I've just returned from 2 weeks' vacation, and face the usual hundreds of emails. Let me just say that I agree with so much of what you have written, that I might have difficulty arguing against it. We in the Research Directorate-General have in general fought for science-based regulation - or indeed no regulation, where the cost-benefit balance does not seem to warrant it - but we have lost many battles over the years, particularly in the area of biotechnology, which I've been following since late 1979.

Your efforts are much appreciated; keep fighting.

Best,

Mark Cantley

Mark.Cantley@cec.eu.int
(RTD)

--------------------------------------------

Fri, Aug 19, 2005 3:26 pm

Dear Mr. Cantley:

Thank you for your correspondence of several weeks ago concerning the ITSSD's recently released study about the precautionary principle's adverse effects on global industry, and in particular, on the American free enterprise system.

Please be assured that the ITSSD and I have written extensively about government and industry use of the precautionary principle as a disguised protectionist trade barrier. We have also not been reluctant to advocate in favor of a case-by-case facts, empirical science and economics (cost-benefit)-based precautionary approach in lieu of a politics and fear-based 'wing-spread' precautionary principle that is premised on a broad administrative presumption of hazard, that is neither sanctioned by WTO law nor by the UN Rio Declaration.

Please also be assured that I have cited and discussed the EU Commission's Communication on the Precautionary Principle in several of the papers I have prepared, including those for the National Foreign Trade Council, now posted on the WTO website.

You are not the first to make the ad-hominem claim that our arguments criticizing how the precautionary principle has been employed (operationalized in EU/UN-speak) by the EU Commission and member state governments is propaganda-based. Actually, Mr. Tony Van Der Haegen, EU Commission Minister-Counselor for Agriculture, Fisheries, Food Safety and Consumer Affairs, formerly of the Delegation of the EU Commission in Washington DC, quite eloquently argued this way almost two years ago, at a joint New York City Bar Association -International Law Association International Law weekend panel discussion. His comments were then subsequently posted on the EU Commission website for the world to see. Unfortunately, however, Mr. Van Der Haegen's near-soliloquy failed to address ANY of the substantive issues discussed in the white papers. Your preliminary comments seem to do the same, but I still have hope. I trust that, as you read the heavily documented papers on the ITSSD website you will come to recognize that the EU Commission needs to publicly address the issues it continues to 'duck', and to not merely respond to popular politics or emotions.

The ITSSD and I welcome the opportunity to meet with representatives of the EU Commission, either in Washington or Brussels, to address the substantive issues, point-by-point, if necessary. Perhaps the EU Commission would consider granting the ITSSD an NGO travel-education grant, much as it has to the environmental and social activists in Europe, to finance such a trip to Brussels, in the name of greater public awareness and transparency.

You and your colleagues at the Commission might wish to consider that at least one European-based free-market think tank agrees with the findings of our study, and has dared to write about them in the Brussels Business Journal. Please see the attached.

http://www.brusselsjournal.com/node/187

We appreciate your interest and look forward to your thoughtful response.

Sincerely,

Lawrence Kogan

Lawrence A. Kogan, Esq.
CEO
Institute for Trade, Standards and Sustainable Development, Inc.
116 Village Boulevard, Suite 200
Princeton Center
Princeton, NJ 08540
(o) 609-951-2222 (c) 609-658-7417 (f) 609-897-9598

ITSSD is a nonpartisan, not-for-profit educational organization dedicated to the promotion of a positive paradigm of sustainable development consistent with free market and WTO principles. Donations and other forms of support are tax-deductible and do not influence the views and policies of the Institute.
-------------------------------------------

Mon 8/1/2005 5:03 AM

Dear Mr Kogan,

Thank you for making available via announcement in AgBioView and the web your ITSSD paper, "Precautionary Preference: How Europe's New Regulatory Protectionism Imperils American Free Enterprise". As I downloaded this from the ITSSD site just a short while ago, I have of course not read it completely, but on going through the Executive Summary, I was struck in section II, "WHAT IS THE PRECAUTIONARY PRINCIPLE?", by paragraph B, "Dispenses With Economic Cost-Benefit Analysis". In this paragraph, you state that "EU regulators who employ the precautionary principle … have dismissed the need to undertake an economic cost/benefit analysis".

I write - in a personal capacity, but as a staffer of the European Commission - to express to you my surprise at this statement. I have tried in a quick search through the full version of your paper to identify any reference to the European Commission's communication on the precautionary principle, reference COM(2000)1. This engaged the efforts of over 20 staff from many services of the Commission during more than a year, and it was not by accident that it received the first reference number of the new millennium - we saw it as a communication of outstanding importance, given the growing pressure from the political side for more explicit attention to the precautionary principle, within Europe and in international instruments such as the Cartagena Protocol on BioSafety.

My search does not indicate any reference to it, though in haste I may have overlooked it; but I attach a copy. Please let me know if I have missed a reference to it in your paper. In the Summary of the communication, paragraph 6 provides this résumé of the key points, discussed in more detail elsewhere in the Summary, and more fully in the body of the paper:

"Where action is deemed necessary, measures based on the precautionary principle should be, inter alia:

 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."

You will note in this the very explicit reference to the use of cost-benefit analysis - quite contrary to the allegation in your paragraph II.B, cited above.

I am concerned myself that we do not always follow the points emphasised in this communication, nor acknowledge the essentially dynamic character of any decisions made under the precautionary principle. But at first glance, it seems to me that your new paper is seriously misrepresenting the position of the Commission. For me, this immediately raises a very basic question about the balance and credibility of your whole paper; and indicates that it is not balanced, but may rather be selective in its choice of materials and its presentation, for essentially propagandist purposes. Given the scale of effort obviously invested in the preparation of your paper, I would be surprised and disappointed; but I confess that I am not familiar with the work of the ITSSD, and am interested to know more about the standards and quality of its work.

I look forward to hearing from you.

Mark Cantley

Adviser, Biotechnology, Agriculture and Food
Research Directorate-General
European Commission

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