Evidently influenced by the UNEP-GEF Biosafety Project, the Biosafety Bill has been drafted principally to implement the Biosafety Protocol verbatim, and in so doing, perpetuates some of the weaknesses and deficiencies of the Biosafety Protocol. For instance, the scope of the Biosafety Bill is predicated on the scope of the Biosafety Protocol where the risks to human health are not central to the biosafety enquiry, but are ancillary to the protection of biological diversity in the use of the terms “taking also into account risks to human health.” (Section 2(1) of the Biosafety Bill; Article 4 of the Biosafety Protocol). The Biosafety Bill also excludes as does the Biosafety Protocol, the transboundary movement of GMOs that are pharmaceuticals for humans that are addressed by relevant international agreements and organisations.
In fact the entire Biosafety Bill is littered with examples of the extent to which the sole imperative underpinning the drafting of the Bill appears to be to implement the basic minimum standards of the Biosafety Protocol. This is dealt with in more detail below, but a striking further example to this effect, is the way in which the documentation to accompany bulk shipments of GMOs has been dealt