SUBMISSION OF OBJECTIONS BY THE AFRICAN CENTRE FOR BIOSAFETY (ACB)
OBJECTION TO MONSANTO’S APPLICATION FOR GENERAL RELEASE OF GM COTTON RR FLEX African Centre for Biosafety, Dec 2005
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Summary
The application is for a general release permit to allow the commercial sale and growing of a new transformation event MON88913, also known as Roundup Ready Flex cotton. The new RR Flex variety ostensibly provides increased tolerance to glyphosate compared to the current product, Roundup Ready cotton line 1445. Use of MON 88913 will enable the application of Roundup agricultural herbicide over the top of the cotton crop at later stages of development than is possible with line 1445.
Monsanto intends to release the new variety, RR Flex during October/November 2006, in Mpumalanga/Limpopo provinces, and will include both irrigated and dryland cotton plantings.
- The notifier claims that there are no wild relatives of cotton in South Africa (5.5 of the application). It has come to our attention that this is not the case and we have a concern that we have been misled by the notifier’s claims in this regard. There are about 39 species of Gossypium. They are found worldwide in the tropics and warm temperate regions with several species cultivated. There are three species in southern Africa, occurring in northern Namibia, Northern Botswana, Northern Province, Mpumulanga, Swaziland and KwaZulu-Natal. These three species of Gossypium are Gossypium anomalum subsp. anomalum which occurs in Namibia, Gossypium herbaceum subsp africanum which occurs in Namibia, Botswana, Limpopo, Mocambique, Swaziland and KwaZulu-Natal and Gossypium triphyllum which occurs in Namibia and Botswana. According to Cotton South Africa and contrary to the notifier claim, cotton does have a wild relative, Gossypium herbaceum subsp. Africanum, found in South Africa . The possibility for gene transfer in locations in Hawaii and Florida, where wild or feral cotton relatives exist has led to the EPA imposing stringent sales and distribution restrictions on Bt crops within these states.
- Monsanto is now seeking a commercial permit based on field trials conducted for only one growing season 2004-5 in respect only of efficacy tests and phytotoxicity characteristics of RR Flex. Despite this, Monsanto makes wide ranging claims of benefits, including: effective weed control, convenience and simplicity, increased grower income, increased adoption of reduced tillage practises, compatibility with integrated pest management, etc., based on assessments conducted in the US;
- Monsanto anticipates that 5000 bags of the RR Flex cotton will be available for planting in South Africa, these “would be used by farmers as a refuge plantings as their preference is to plant “stacked” variety (BGRR). We find this extremely disconcerting, in the light that even in Monsanto’s own literature, a compulsory refugia of 20% is supposed to be planted with non-transgenic cotton;
- We are concerned about the implications arising from the use of RR Flex and the stacked varieties involving herbicide tolerant crops for agricultural workers and small scale farmers in terms of food and job security, particularly in view of there being no socio-economic studies available that addresses these concerns;
- Genetic modification by the application of recombinant DNA technology is characterised by scientific uncertainty. This stems from several factors including the inherent imprecision of currently employed recombinant DNA techniques, the use of powerful promoter sequences in genetic constructs and the generation, as a result of genetic modification, of novel proteins to which humans and animals have never previously been exposed;
- 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;
- RR Cotton was denied regulatory approval by the European Commission in 1999 because of concerns about the aad resistance marker;
- The US experience of Roundup Ready field trials has shown a marked increase in herbicide usage, particularly glyphosate; and
- In the Argentinean experience, the large-scale uptake of Roundup Ready Soya has had devastating impacts on food security and the environment.
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