• Objection To The Application By Syngenta For Commodity Clearance Of Syngenta Mir604 Maize To The National Department Of Agriculture, South Africa African Centre for Biosafety, 27 May 2005

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The discussion below details our concerns against the possible granting of a permit to Syngenta for the commodity clearance of MIR604 maize against the background of both scientific and historical evidence that points to the need for more rigorous testing of the event in question. In summary our concerns are:

  • The safety approval sought by Syngenta in respect of genetically modified (GM) maize MIR 604, still subject to field tests in the US, appears to be in conflict with the principles and provisions of the Cartagena Protocol on Biosafety to which South Africa is a Party, because the Protocol applies to real situations of cross border trade in genetically modified organisms (GMOs) and not to speculative trade in respect of non- existent GMOs.
  • The currently applied techniques for the genetic modification of higher plants is imprecise and exposes consumers to powerful promoters usually of non-food origin to which they might not ordinarily be exposed. The impact of such exposure is not sufficiently well understood.
  • The event MIR604 is still in experimental stage in the United States and the application for clearance of MIR604 is still pending in the United Kingdom. South Africa should be as or more rigorous in its assessment of applications for GE foods.
  • Several mainstream American food companies such as McDonalds and Kraft which have international footprints are not sourcing even approved GM foods because of negative consumer responses to their use. Further these companies are requiring more stringent testing than that applied by the US authorities.
  • The US Environmental Protection agency (EPA) has granted a temporary exemption of a requirement from tolerance to the modified cry3A protein found in event MIR604. The EPA has for several similar applications by developers of GE foods not applied its own minimum assessment criteria and there is an apparent bias towards GE foods in the US. The South African Authorities should not take its cue from the US EPA.
  • The methods applied by the US EPA for allergenicity testing is not in compliance with the widely adopted 2001 FAO-WHO standard, a standard required by Kraft foods.
  • The digestive stability test accepted by the US EPA in the assessment of MIR604 does not meet the standard and is not in accordance with the protocol of the FAO-WHO and is in fact applied by the developer of MIR604 at pH 1.2, a pH more likely to show digestive stability than the widely accepted pH 2.0.
  • Cry3A, of which the modified form mCry3A is found in MIR604, has been found to have sequences homologous to a known allergen which raises the possibility that mCry3A is a potential allergen.