Objections to Permit Applications

Objections to Permit Applications

Objection to applications made by the South African Sugar Research Institute (SASRI) for trial releases of GM sugarcane

The South African Sugarcane Research Institute (SASRI) has applied to the Department of Agriculture, Forestry and Fisheries for permission to conduct field trials for 4 varieties of GM sugarcane. Having viewed SASRI’s applications in terms of the Public Access to Information Act (PAIA), it is our opinion that the information provided is so inadequate that it is virtually impossible to conduct any meaningful independent assessment of the applications. Further, throughout the application runs the assumption that the genetically modified lines under discussion are ‘equivalent’ to their conventional counterparts. This is a view not supported by the published literature.

The African Centre for Biosafety hopes that the Executive Council considers our very real concerns when deciding over this application. In the interests of the biosafety debate in South Africa, we also respectfully request that the Executive Council establishes a formal process whereby it, rather than the developers of GMOs, decides what constitutes ‘confidential business information’, and what constitutes information for the public interest.

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ACB’s Objection to Pioneer Hi-Bred’s commodity clearance application for GMSoya 305423 x 40-3-2

The ACB has come to the following conclusions about Syngenta’s application:

In terms of the molecular characterisation of the event:

  • It indicates several irregularities including open reading frames and a truncated constructs which could give rise to unintended gene effects
  • The transfer of the herbicide-tolerant trait to weeds could result in increased herbicide application. The potential for economically important weeds developing herbicide tolerance is a cause for concern
  • Glyphosate use has resulted in several unwanted effects on aquatic systems and terrestrial organisms and ecosystems
  • The US experience of Roundup Ready field trials has shown a marked increase in herbicide usage, particularly glyphosate
  • In the Argentinean experience, the large scale uptake of Roundup Ready Soya has had devastating impacts on food security and the environment

Furthermore, it is our contention that:


  • Reliance on the assessments of EFSA is fraught with problems given the criticisms and contradictions inherent within EFSA especially in respect of its methodologies and perceived pro-industry stance, which it is itself grappling with
  • The claims of the increased yield performance of GM crops are unsubstantiated
  • GMO plantings contribute to increased rather than reduced pesticide use
  • It is disingenuous to suggest that planting of GM crops will contribute to

ACB’s objection to Monsanto’s application for extended field trials of drought tolerant maize

In 2007 Monsanto South Africa applied for and was granted a trial release permit to conduct field trials with maize event MON87460, which has been genetically engineered for drought tolerance. Earlier this year the African Centre for Biosafety objected to a Monsanto application to import 35 hybrids for the continuation of these trials. Monsanto submitted a response to some of our concerns to the Department of Agriculture, Forestry and Fisheries, which we have been able to view. Monsanto’s response, and its latest application still leaves much cause for concern.

We reiterate Monsanto’s own expressions of doubt as to potential yield benefits of MON87460, and ask again how these meagre benefits can be justified when considering the considerable risk that the MON87460’s introduction into the environment would entail?

Information crucial to a thorough and independent assessment of the transgenic event is again missing, kept out of the public realm under the dubious moniker of being ‘confidential business information’. As such, their application is littered with claims of yield performance and apparent safety which cannot be corroborated.

The consultation process is not sufficiently long enough to enable full and meaningful public participation. The fact that the South African regulatory authorities have failed

ACB’s objection to Monsanto’s commodity clearance application for Smartstax

In the 20th of April the Business Day newspaper carried a public notice of Monsanto‘s application to the South African GMO registrar for permission to import Smartstax maize, arguably the world’s most controversial and risky commercially grown GMO. While the majority of commercially grown genetically engineered crops contain at most 3 foreign genes, Smartstax contains eight, 6 of which are for insect resistance and a further 2 for resistance to chemical herbicides. Smartstax was granted approval in the US and Canada on the basis that the parent GM maize lines that were cross bred to create it were previously classified as safe, meaning that Smartstax has not even been subject to proper risk assessment! Several prominent biosafety experts at the United Nations have already expressed their dismay at this assumption of safety, while the issue of stacked GMOs is set to be a major area of contention at the upcoming Convention on Biodiversity meeting in Japan later this year. Having viewed Monsanto‘s application (in accordance with our constitutional rights), the African Centre for Biosafety has written to the GMO registrar expressing our grave concerns over several risks we were able to identify from the limited information

ACB’s objection to Monsanto’s application for trial release of drought tolerant GM maize MON 87460

Monsanto has been conducting field trials of drought tolerant maize in South Africa since 2007, and has recently applied to have these trials extended. Monsanto has presented the trials as forming part of the much larger Water Efficient Maize for Africa (WEMA) Initiative, of which the African Centre for Biosafety has already criticised in a previous publication. Having viewed, the albeit exremely limited ‘non-confidential-business-information’ version, of Monsanto’s appeal document, the ACB feels it pertinent to bring several glaring concerns of ours to the public attention.

Drought tolerance in plants is an incredibly complex characteristic, involving up to 60 seperate genes (remember the majority of commercially grown GM crops contain just 1 or 2 artificially inserted genes). Monsanto even admits in its application that under conditions of extreme drought, the apocalyptic visions of which the biotech industry frequently uses to justify its activities, MON 87460’s yield ‘can be reduced to zero’. Bearing this in mind, and taking into consideration the very real risks we have identified from Monsantos application, including horizontal gene transfer, the use of anti-biotic resistance marker genes and the danger of cross pollination with conventional vareties, we fail to see how the continuation of these trials can be

ACB’s Objection to Syngenta’s application for general release of GM maize GA21

On 13th of December 2009, Syngenta published a public notice of their intent to apply to the GMO Registrar for a permit for the general release of genetically modified maize, GA21. Having obtained a ‘non-confidential-business-information’ version of Syngenta’s application, it is our contention that the application cannot be adequately assessed. The information provided is sketchy at best, key information required for a full and thorough assessment of the event in question is designated confidential business information and therefore not made available to the very public who are expected to consume the product. Claims made regarding gene stability are by reference to information provided by the developer of the GMO and not to any independent, objective source. Additionally, assertions made as to the socio-economic benefits pertaining from a general release of GA21 are grossly misleading and do not hold up to objective scrutiny.

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In 2009 section 78 of the Biodiversity Act was amended, and now provides that:

‘…if the Minister has reason to believe that the release of a genetically modified organism into the environment under a permit applied for in terms of the Genetically Modified Organisms Act, 1997 (Act No. 15 of 1997), may pose a

ACB’S Objections to Syngenta’s application for field trials of GM Maize

Prepared for the African Centre for Biosafety by
Dr William Stafford
September 2009

Description of Application

GA21 and Bt11xGA21 transgenic maize are genetically modified maize events. The Bt11xGA21 stacked maize was produced by the conventional breeding of individual GA21 and Bt11 transgenic events.

GA21 maize produces a modified maize 5-enolpyruvylshikimate-3-phosphate synthase enzyme (mEPSPS) that confers tolerance to herbicide products containing glyphosate.

Bt11xGA21 maize produces modified maize 5-enolpyruvylshikimate-3-phosphate synthase enzyme (mEPSPS) that confers tolerance to herbicide products containing glyphosate; as well as a truncated Cry1Ab protein for control of certain Lepidopteran pests and a phosphinothricin acetyltransferase (PAT) protein that confers tolerance to herbicide products containing glufosinate ammonium.

This application is for the continued field trials of GA21 and Bt11xGA21 (Syngenta).

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