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18th May 2007
OPEN LETTER
Dear Harry
A Proposal for Urgent Action by EFSA on GM Science
As you are aware, GM Free Cymru has, on many occasions in the past,
raised with EFSA the overwhelming emphasis placed by you and other
regulators and advisory committees on "advocacy science" when you
are
considering the health, safety and environmental impacts of GM crops
and products (1). Our concerns were brought into sharp focus when we
recently attended the 3rd European Conference of GMO-Free Regions in
Brussels, when speaker after speaker demonstrated a deep mistrust of
EFSA and called for reforms in its membership and in its operational
methods. Your GMO Panel is widely viewed as being "in the pocket" of
the biotechnology industry, and as a body which exists not for the
protection of the public but for the facilitation of GMO consents.
This perceived industry bias has caused concern within the EC and in
the European Parliament, and although EFSA committed itself more than
a year ago to greater transparency and dialogue with stakeholders, we
see little sign of any change. The statements on openness,
transparency and independence on the EFSA web site have done nothing
to allay our fears.
We appreciate that this sorry situation is not entirely of EFSA's own
making, in that you have no funds for extensive independent
laboratory research and in that you can only make scientific
judgments on the basis of what is presented to you in dossiers or in
ancillary pieces of research which you may request. However, as we
have seen from the fiascos associated with MON863 and MON810, the
instinct of those who are applying for GMO consents is always to
present the "best" possible case (through the use of corrupt science
and in-house data manipulation if needs be), to seek to prevent open
access to their dossiers, and to dismiss any criticism or questioning
of their methods or research findings. They systematically vilify
or patronise those who conduct (with great difficulty) genuinely
independent research. Corporations such as Monsanto routinely block
such independent research by denying access to their GM materials by
any researchers whom they deem to be "unfriendly." Their research
is
therefore non-replicable, in contravention of one of the oldest
principles underpinning scientific endeavour. We have documented
many such cases (2), and Monsanto, Syngenta and other companies have
never denied their behaviour in this respect. Jeffrey Smith's new
book contains many more examples of the manner in which the GM
corporations have twisted science for their own ends.
As long as EFSA's GMO Panel allows itself to be associated with this
sort of scientific corruption, it will not win any increase in
approval or trust from NGOs, consumer groups and the general public.
May we suggest one very simple way out of this profoundly depressing
situation? EFSA should issue a simple statement (3) along these lines:
"In the interests of public safety, EFSA will not consider any
dossier or any other research material submitted in support of an
application for a GMO approval unless (a) it is accompanied by a
signed declaration to the effect that the scientific research
(including full data sets) will be open to public scrutiny and peer
review; and (b) it is accompanied by a signed declaration that
repeat, additional or extended experiments by bona fide independent
researchers and laboratories will be facilitated through the
provision of GM reference materials as appropriate."
Such a statement issued by EFSA, and strictly adhered to, would in
our view go a long way towards the restoration of confidence in the
GMO Panel -- and it would, for the first time, allow truly replicable
science to become a part of your operations. If Monsanto or any of
the other corporations should refuse to sign these two simple
declarations, we can draw our own conclusions as to the honesty of
their science and the safety of their GMOs.......
We ask you to take this proposal to your GMO Panel as a matter of
urgency, and also to seek the approval of EFSA as a whole.
We are treating this as an Open Letter, and hope that other
organizations and individuals will (if they have not done so already)
ask you to make this simple and entirely legal step, in the interests
of sound science, public safety and environmental protection.
We look forward to hearing from you with confirmation that you will
take this matter forward.
Yours sincerely,
Dr Brian John
GM Free Cymru
Trefelin, Cilgwyn, Newport, Pembs SA42 0QN, Wales
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NOTES
(1) http://www.gmfreecymru.org/pivotal_papers/manipulation.htm
http://www.gmfreecymru.org/pivotal_papers/corruption.htm
http://www.gmfreecymru.org/pivotal_papers/greenpeace.htm
http://www.gmfreecymru.org/pivotal_papers/syngenta.htm
(2) http://www.gmfreecymru.org/pivotal_papers/manipulation.htm
(3) We would of course accept that certain very limited information
(relating to DNA, gene sequences etc) should remain as commercially
confidential information. But the CBI label has been grossly
misapplied in the past, by EFSA among others, against the public
interest -- and it is time that the regulators, rather than the GMO
consent applicants, made the decisions as to what material genuinely
deserves protected status.