GENTECH archive 8.96-97

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FOEE Mailout



  														
						FRIENDS OF THE EARTH EUROPE
														
						BIOTECHNOLOGY PROGRAMME



Mailout Vol. 2 (1996)											
Issue 6, 15th September 1996



FoEE WORKSHOP ON INTERNATIONAL BIOSAFETY

The Biotechnology Programme of Friends of the Earth Europe held a Workshop 
on International Biosafety on 12 & 13th September 1996 in Brussels.  The 
workshop, which was attended by more than 70 participants from over 16 
countries, including Togo, Benin, Indonesia, Cameroon, Ghana, Argentina, and 
Georgia, brought together scientists as well as experts and representatives 
from numerous non-governmental organisations, from industry and the European 
Commission.

The workshop gave an overview of North-South transfers of genetically 
modified organisms which have taken place in the past, of the experiences 
with international regulations in the field of transfers of hazardous 
chemicals, and finally focused on the elements which a biosafety protocol 
could include.  A panel discussion with representatives from industry (Asgrow 
Seeds; Sandoz), NGOs (Third World Network; Greenpeace; Friends of the Earth 
International), and the European Commission completed the workshop.  The 
conference folders with abstracts of the presentations are available on 
request from the FoEE Biotechnology Programme in Brussels (see address at 
the end of this mailout).

The background
The primary goal of the workshop was to discuss the on-going negotiations of 
the biosafety protocol which are taking place at the moment under the umbrella 
of the Convention on Biological Diversity.  Although, after years of debate, 
the Conference of the Parties to the Convention on Biological Diversity had 
settled at its 1995 meeting in Jakarta the terms of reference for an open-
endedad hoc working group on biosafety, it did not address the question of 
which aspects the protocol should actually cover.  The mandate as adopted in 
Jakarta circumvents the most controversial issue of the scope of the protocol 
by only calling upon the open-ended working group to "develop in the field of 
the safe transfer, handling and use of living modified organisms, a protocol 
on biosafety, specifically focusing on transboundary movement".  However, 
guiding principles for the Working Group are to take into account the 
principles of the Rio Declaration, in particular the precautionary approach.  
The working group is supposed to complete its tasks by 1998.

The decision in favour of a protocol was seen by many as a major victory of 
developing countries which have been urging the world community since 1992 to 
start work on a protocol.  Facing the demand of G77 countries and the 
increasing attention the issue received by the Northern press and  public, 
the original opponents of the Protocol, such as the EU and Japan, finally 
gave in and accepted a decision which is more far-reaching than most 
observers had expected.  The US, not yet a Party of the Convention and, 
therefore, not a candidate for the protocol, still seems to have serious 
reservations, but decided, nevertheless, to participate actively in the 
negotiations.

However, the first meeting of the Open-ended Ad Hoc Working Group on Biosafety
held in Aarhus, Denmark, from 22 - 26 July 1996, raised serious doubts about 
whether the contracting parties will succeed in completing their work on an 
International Biosafety Protocol in 1998.  Instead of starting negotiations on
the items which according to the decision of the 2nd Conference of the Parties
 should be regulated by a Biosafety Protocol, the BSWG only adopted a working 
paper on the structure of a future protocol which falls into three sections.  
Section 1 lists items which all delegations wished to be covered by the 
Protocol.  Such items were basically only information-sharing, an advanced 
informed agreement procedure in case of transboundary movements and an 
institutional framework for the functioning of a Protocol.  Section 2 of the 
working paper identifies those items which were proposed by some delegations 
only, while section 3 lists terms proposed for definition.  Apart from the 
working paper, which observers described as a shopping list due to its 
vagueness and openess, the BSWG adopted two recommendations to the Conference 
of the Parties which will meet in Buenos Aires in the first half of November.
  The working group proposes to the Conference of the Parties to consider the 
establishment of a permanent Bureau for the biosafety working group.  
Furthermore, it suggests, depending on sufficient funds, that the group should
hold two five-day meetings in 1997. 

Whether the protocol will be ready in time for adoption in 1998 might largely 
depend on whether the contracting parties achieve consensus on its scope in 
the meantime.  According to Christoph Bail, Head of Unit at the European 
Commission, the Protocol should focus on transboundary movement, if the 
deadline of 1998 is to be met.  However, consensus on the scope of the 
protocol still seems difficult to achieve.  Bail pointed out that even among 
the Member States of the Euopean Union there is not yet consensus on the 
scope.  While the Scandinavian countries favour a rather broad protocol which 
would include provisions on domestic handling and use of genetically modified 
organisms as well as provisions on liability and compensation, countries like 
Germany, the Netherlands, and the United Kingdom favour a narrow scope and the
so-called two-track approach, having a protocol focussing on transboundary 
movements of GMOs and the voluntary UNEP Technical Guidelines covering all 
other aspects. 

North-South Transfer
Although the majority of field releases of GMOs have been carried out in 
Northern countries, an increasing number of releases is being conducted in the
South.  
Ivar Virgin from the Stockholm Environment Institute pointed out that "many 
developing countries have served as winter nurseries and counter season seed 
production sites for private corporations".  Virgin emphasized that "while the
large majority of industrialized countries have biosafety regulatory 
procedures in place, the situation in developing countries is dramatically 
different".  Under these circumstances, it seems clear that biosafety 
regulations urgently need to be introduced in countries which so far lack any 
regulations. However, Helge Torgersen fom the Institute for Technology 
Assessment (Austrian Academy of Sciences) questioned the value of the risk 
assessment procedure as foreseen, e.g. by the European Directive on the 
deliberate release of genetically modified organisms.  Thorgersen presented a 
study which is based on three case studies carried out in Austria in 1995.  
The study ("Ecological impacts of traditional crop plants - a basis for the 
assessment of transgenic plants?") concludes that the significance of the 
parameters "gene transfer" and "invasiveness" is much lower than their 
importance for the currently practised form of risk assessment.  On the other 
hand, ecological impacts that are of major practical importance (especially 
those resulting from a change of agricultural practice) are not taken into 
account by the risk assessment procedures currently practised in the North.  
Torgersen suggested assessment on a case-by-case basis whether the genetic 
modification allows, promotes or requires changes in agricultural practice and
the possible environmental impacts resulting from such changes.  Furthermore, 
Torgersen proposed, "to introduce in the long term more 'ecological' breeding 
goals in terms of a prophylactic and extensive environmental protection. "

Experiences to learn from

Brenda Bender (UNEP) and Peter Beaumont (The Pesticides Trust) presented the 
FAO/UNEP Joint Programme on the operation of the prior informed consent (PIC) 
procedure in the field of chemicals and pesticides.  The existing PIC 
procedure has been in operation for 5 years now and the Joint Secretariat, 
together with the designated national authorities in over 140 countries built 
up substantial experience in its implementation.  Although the voluntary 
procedure has been successful so far, there are some limitations, and 
governments now see a need to go a step further and adopt mandatory controls 
on trade in hazardous chemicals and pesticides.  Both the FAO and UNEP have 
mandates from their governing bodies to convene negotiations to develop a 
legally binding instrument on PIC.  The Intergovernmental Negotiating 
Committee met for the first time in March of this year in Brussels.  The final
session of the committee is envisaged to be held in the first half of 1997 in 
the city of Rotterdam.  The documents are available from UNEP's www-site 
<http://www.unep.ch>.

In his evaluation of the current PIC procedure Peter Beaumont identified 
several areas of concern.  Beaumont pointed out that limited resources had 
hampered the implementation of the PIC procedure.  "This has delayed 
completion of an effective data base and of the Decision Guidance Document 
needed to bring more chemicals into the PIC procedure".  After more than four 
years, only 17 chemicals have been included in the PIC procedure.  Beaumont 
made it very clear that the existence of a biosafety protocol would mean 
nothing if countries lack the necessary capacity to implement it.

The Biosafety Protocol and the Issues of Trade and Liability
Barbara Eggers from the Foundation for International Environmental Law and 
Development (FIELD) gave an overview of the requirements of the WTO Agreement 
in relation to transgenic organisms.  In principle, the Agreement on the 
Application of Sanitary and Phytosanitary Measures, which forms part of Annex 
1A of the WTO Agreement allows Members to take sanitary and phytosanitary 
measures.  However, the Agreement includes several obligations and minimum 
requirements, e.g. in relation to the assessment of risks and the 
determination of the appropriate level of sanitary or phytosanitary 
protection.  In particular, the Agreement allows measures only to the extent 
necessary to protect human, animal or plant life or health.  In addition, 
Members have to ensure that the measures are based on scientific principles 
and are not maintained without sufficient scientific evidence.  According to 
Eggers, the WTO Agreement, although it sets certain minimum requirements, 
does not prevent Member States from effectively controlling trade in GMOs.  
There is still much scope for trade-effective measures in the biosafety 
protocol, Eggers concluded.

Ruth Khalastchi (FIELD) presented a study on an issue which is still very 
controversial among the negotiating parties in the biosafety working group: 
the issue of  liability and compensation.  Khalastchi pointed out that civil 
liability regimes on hazardous activities or substances and their 
transboundary movement are fairly well developed in international law.  The 
existing regimes (e.g. the 1993 ("Lugano") Convention on Civil Liablity 
Resulting from Activities Dangerous to the Environment) may provide some 
useful models in addressing the core issues.  However, the particular nature 
of living modified organisms may require new approaches to some of the 
fundamental issues, e.g. the question of limits on the time within which a 
claim can be brought.

The Biosafety Protocol under Debate

The final session and the panel discussion which concluded the workshop made 
very clear that NGOs and industry are far away from any consensus.  Hira 
Jhamtani (Third World Network), Jesper Grolin (Greenpeace), and Rod Leonard 
who presented the Community Nuitrition Institute Draft Biosafety Protocol 
emphasized that the biosafety protocol needs to cover the use, handling and 
transfer of all genetically modified organisms and called for liability 
provisions to be included in the protocol. In their opinion the biosafety 
protocol should also allow import decisions to be based on socio-economic 
considerations. The representatives from Asgrow/Bruinsma Seeds, Leo van den 
Berkmortel, and from Sandoz, Helmut Bachmayer, stated that their companies 
would act in complicance with the safety standards required in industrialised 
countries even where these standards are not required, as is the case in many 
developing countries.  Asgrow Seeds rejected, in particular, reproaches from 
Greenpeace International, according to which the company had released in 1994 
genetically engineered tomatoes, squash and cantaloupe in Guatemala without 
informing the competent authorities of Guatemala in advance.  Asgrow offered 
to provide Greenpeace with a copy of the import certification.  Greenpeace 
International responded by asking why this offer came so late, recalling 
Asgrow that the company had known about the case study carried out by 
Greenpeace since the Aarhus meeting in July.

Bachmayer summarized the position of the international biotechnology industry 
as follows: "An international biosafety framework needs to be science-based 
and directed at the product, not the process.  It should fully integrate the 
mutual recognition of data and accept the concept of substantial equivalence.  
Any new regulation must aim at greater harmonisation of existing systems". 

The meeting highlighted the importance of international biosafety regulations.
It also showed that the way to a binding biosafety protocol might be long if 
industrialised countries continue to insist on excluding essential aspects of 
biotechnology from the scope of the protocol.

(DL)


OPPOSITION TO GENETICALLY MODIFIED SOYBEANS

On September 11th, 1996, Greenpeace Germany, in cooperation with BUND/Friends 
of the Earth Germany and with the support of the Arbeitsgemeinschaft der 
Verbraucherverbande (AgV, a consumer organisation), started their campaign 
against the placing on the market of the genetically modified soybean from 
Monsanto.

The organizations have started a survey within food producers to find out 
about their plans concerning the use of products from genetically modified 
soybeans.  An initial success was the response from the Union of Diets, whose 
members include companies producing baby food such as Hipp, Humana and Milupa.
 They are planning to guarantee that genetically modified soybeans will not be
used.  Greenpeace will ask its 500,000 supporters to focus particularly on the
big processing companies, such as Unilever, Nestle and Danone, to encourage 
them not to use genetically engineered soybeans.  BUND/FoE Germany is also 
organizing an information tour through some 50 cities in Germany at the same 
time.

According to an opinion poll carried out by Emnid on behalf of Greenpeace, 87%
of consumers would boycott products from companies using genetically 
engineered food.  If the big companies, such as Unilever, Nestle and Danone 
were to follow such consumer opinion and reject the use of genetically 
modified foods, there would be no market for these products in Europe.  The 
public is also very concerned that no attempts have been initiated to 
guarantee a separation between conventionally produced and genetically 
modified soybeans, although some importing companies have already stated that 
separation is possible, - which is exactly the opposite of what Monsanto, the 
ASA and large  processing companies have been arguing since the beginning of 
the debate.

Consumer concerns are - as often claimed by industry representatives - not 
limited to Germany.  Similar campaigns have started recently in Switzerland, 
supported by a broad coalition of environmental and consumer organizations, 
as well as in the USA itself.  In the Netherlands, Stichting Natuur & Milieu 
has left the round table established several years ago by Unilever and Dutch 
environmental and consumer organizations because Unilever could not agree not 
to use products made out of genetically modified soybeans.  The debate has 
also become increasingly heated between retailers and manufacturers in the 
United Kingdom during the past couple of months.  EuroCommerce, which 
represents one third of all European retailers, wrote to the American Soybean 
Association in July saying European Commerce insists that in order to ensure 
consumer confidence, consumers must receive full information on foodstuffs 
they wish to purchase, thus allowing them to make an informed choice.  This 
was followed  by a statement from the British Retail Consortiums Director of 
Food and Drink, Janet Nunn, in August : Retailers in the U.K. and Europe as a 
whole are clear that the preservation of consumer choice is paramount and that
substantial work over several years on product and ingredient labelling should
not be compromised.  In this respect, the mixing of genetically modified and 
conventional soybeans from the 1996 USA crop due for harvest this autumn is 
unacceptable, and retailers fully expect that systems be implemented to 
separate modified from conventional soybeans so that the consumers right to 
choose is preserved.  Should full aggregation of the 1996 harvest in the USA 
not be achieved, British and other European retailers are fully prepared to 
take the appropriate action to develop alternative sources of conventional 
soybean or reformulate products to utilize soya alternatives in order to 
maintain the consumers ability to exercise informed choice.  The U.K. Food 
and Drink Federation (FDF) responded to mounting pressure with statements 
such as : .... consumers will be offered choice through the final sanction of 
avoiding products containing soya as an ingredient if the use of this 
particular GM application is of concern to them (source : letter to The 
Genetics Forum from Joanna Scott, 19.08.96).

Bearing in mind the intensity of the public debate on the application of 
genetic engineering in the past, the current situation of public concern and 
also the fact that consumer and environmental organizations are campaigning 
against the placing on the market of a herbicide resistant soybean could have 
been anticipated.  Therefore, the American Soybean Association and also the 
Verband der Olmuhlen (Union of the Oil Mills, handling some 5M tons of 
soybeans a year in Germany alone) were quite proactive in attempting to 
convince journalists, and also to some extent the wider public, that there 
are no environmental or health problems related to the new soybean.  They 
even established an information office in Frankfurt, working only for 
this purpose.  How nervous companies are can be guaged from the fact that the 
proceedings of a press conference by BUND and Greenpeace was secretly audio-
taped and reported.  (Unfortunately, we cannot as yet provide our readers 
with the address where you can order the transcript in case you are 
interested!)

(JK including information from The Genetics Forum)


COMMISSION STILL EVALUATING CIBA GEIGYS GENETICALLY MODIFIED MAIZE

It came as no surprise that the Commission has had to once again postpone the 
decision on whether to authorize Ciba Geigys genetically modified  maize.  
This was predictable given both the complexity of the subject and the fact  
that the three different committees which the Commission  elected to consult 
in  the  decision-making procedure  -  the  Scientific  Commitees  on Food, 
Animal Nutrition and Pesticides - did not have the opportunity to meet during
the  vacation  period  in  August.  Instead, the committees were due to meet 
for the first time during the first week of September.  The chairmen of the 
three committees will then report to Commissioner Bjerregaard once conclusions 
have been reached, which is not now expected to happen until October or 
November.

The situation, therefore, is that the time period foreseen under Directive 
90/220/EEC has elapsed (on 31st August) with no decision being reached.  
However, the Commissions legal advisers have indicated that because 
additional scientific evidence has been presented, the deadline is no longer 
valid.  It is also highly unlikely that Ciba Geigy will attack the Commission 
for not acting within the prescribed time frame since the multinational 
company proclaimed, in a press release at the end of July, that it fully 
supported the  Commissions  action to postpone the decision pending 
consultation with the three scientific committees.

Once the evidence of the three scientific committees has been presented to 
Mrs. Bjerregaard, the Commission can still take the final decision concerning 
authorization of the Ciba Geigy if it sticks to its original proposal.  If, 
however, the Commission decides that the proposal should be modified 
following the opinion of the scientific committees, then it has to go back to 
the Council of Ministers.  The latter is the more probable outcome, according 
to a Commission spokeman who was quoted as saying that the situation "has 
changed quite a lot since the first proposal".

In another development, a Commission spokesman told the press on 4th September
that EU member states will have to ensure that unauthorized (i.e. genetically 
modified) maize which is not authorized in the Union is not put on the market 
on their territory.  Such checks should begin once the first imports of US 
maize arrive in Europe.  How to differentiate between normal and genetically 
modified maize, however, is extremely unclear and, according to one U.S. farm 
official in Brussels, there is no guarantee that genetically modified maize 
will not get into the export channels.  In this connection, Greenpeace, in a 
press release dated 30/8, announced that Ciba Geigy is planning to import 
genetically modified maize for human consumption from the U.S. this autumn.
According to the same press release, in   another development, the U.S. 
Environmental Protection  Agency  has issued  an "extremely restrictive" 
licence to the Northrup King Company to sell genetically modified maize 
containing the insecticide bt toxin in the new world.  As it happens, 
Northrup King is a subsidiary  of  Sandoz, which is currently in the process 
of merging with Ciba Geigy.

(GL)


DIALOGUE ON GENETICALLY MODIFIED FOOD ENDS WITHOUT SUCCESS

About two years ago, BUND/Friends of the Earth Germany initiated with Unilever 
a round table discussion on novel foods.  This round table was joined by 
several other groups including the Verbraucherinitiative (VI, consumer organ-
ization), the Union of Housewives (DHB), the trade union for food (NGG), a 
research institute (Katalyse) and the retailer SPAR.

The goal of BUND was not only to clarify its rejection of genetic engineering 
in the food sector but also to find a coalition partner for an agreement on 
extensive labelling - one of the major points of debate within the Novel Food 
Regulation.  Furthermore, we tried to discuss the relationship between the 
existing conditions concerning the production and distribution of food and the 
ecological and socio-economic impacts.  Unfortunately, the debate focused too 
intensively on the evaluation of the single enzyme, Xylanase, used in the 
baking industry, and no agreement could be found on the other goals.

On September 9th, the round table presented the results of their work at a 
press conference.  The participants - excluding BUND - produced a common paper,
while BUND presented its own minority paper.  In its statement, BUND expressed 
its disagreement with the final communique of the round table and with the 
dossier concerning the safety of the enzyme Xylanase.  The main points of 
concern were :

1.	Limitation on Xylanase.  The goal of the evaluation of xylanase had been 
to break down the abstract potential risks usually named in the discussion on 
the application of genetic engineering in the food sector, and how these risks 
can be verified or falsified.  The extremely time consuming process, focusing 
on xylanase itself, however, did not meet the general expectations which BUND 
had anticipated in this round table discussion.  NGOs do not have the task of 
a second competent authority responsible for the authorisation of the product.

2.	Who needs Xylanase?  The communique concerning the evaluation of the 
enzyme xylanase does not cover several important aspects.  There has, for 
example, never been a debate on the necessity of the usage of the genetically 
engineered xylanase.  In addition, alternative methods were not assessed and 
compared.  These questions are of importance inasmuch as even the best risk 
assessment cannot predict all potential - especially long term - risks related 
to a product, in that a risk assessment also has to cover the balance between 
potential risks and benefits which would make it worthwhile to accept a 
certain level of risk.

3.	Toxicity and allergic potentials of Xylanase.  BUND is not satisfied with 
the results of the evaluation of the product safety.  Feeding tests, for 
example, have shown significant differences in the animal population so that 
further tests are necessary in our opinion. Concerning the allergic potential, 
the assessment has fundamental weaknesses.  In 1970, only 300 cases of asthma 
occurring in bakers were identified whereas in 1989 more than 2000 cases were 
notified by the health insurance companies.  The reason for this increase lies 
in the extended use of enzymes in flour.  The relevant question is thus 
whether it is appropriate to have even more enzymes in use - genetically 
engineered or not.

4.	No recommendations concerning labelling.  The round table could only 
agree on a very weak statement concerning the labelling stating the consumer 
has the right to get all information important and relevant for him. During 
the press conference, Unilever stated that they do not intend to have 
labelling which is beyond the regular laws.

5.	No recommendations concerning the safety of the production process.  The 
recommendations concerning the production safety are only limited to xylanase. 
 Therefore, the opportunity has been missed to make a clear statement on the 
planned deregulation of the EU Directive 90/219/EEC on the contained use of 
GMOs.

6.	A Directive for all enzymes.  At a time when the conciliation procedure 
on the novel food regulation is not finished, BUND could not agree with the 
opinion of the other participants of the round table to have an enzyme 
directive as proposed by the AMFEP.  BUND feels that the Novel Food Regulation 
is the appropriate place to also regulate enzymes produced by genetic 
engineering.
 
7.	The differences were greater than the common interest.  There was no 
final agreement on the scope of labelling, regulated by the Novel Food 
Regulation, nor on the safety standards related to the production of enzymes.  
In addition, it was difficult for us to understand why Unilever has, on the 
one hand shown a very open approach and on the other hand, the SAGB (Senior 
Advisory Group on Biotechnology of which Unilever is a member) has lobbied 
against a progressive novel food regulation.



COMMENTARY :  GENERAL PROBLEMS RELATED TO THE "ROUND TABLE DISCUSSION"

The experience BUND has had with several round table discussions indicate 
that there are clear limitations concerning the results of such discussions 
and, furthermore, that these discussions can only be successful if several 
points are seriously taken into account in advance.

	1.  First of all, we have to analyse whether the formulation of the aim 
of the project is in line with the political goals which are intended by 
using the results of the project.  To confine the debate to technical 
questions - which implies that if all these questions are answered within the 
discussion no risk is related to the application of genetic engineering - is 
wrong.  Assessing the quality of welded seams in a nuclear power plant does 
not, for example, say anything relevant about the safety of nuclear power 
technologies in general, nor anything about public acceptance in particular.  
Other factors such as, for example, the impact of the product on the further 
concentration process in a specific branch of industry or on destruction / 
establishment of working places, are of the same importance for many NGOs 
when assessing the application of genetic engineering.  A good example might 
be the growth hormone rBST, which has been opposed not only because of health 
concerns but also because of questions related to animal welfare and concerns 
related to the further development of the agricultural system in the European 
Union.  Socio-economic questions are usually a topic companies are not very 
interested in discussing whereas these questions are crucial for NGOs. 

	Another topic of importance for the assessment of a product is the simple 
question : how useful is the product.  Although it might be extremely 
difficult to define concrete criteria on what is useful or necessary, this 
question is also of relevance because no risk assessment could assess all the 
potential negative side effects in the long-term.

	2.  A single product evaluation is extremely technically oriented.  
Former experiments with technology assessment (TA) clearly indicate that a 
problem oriented approach should be preferred instead of a purely 
technological oriented approach.  It is therefore absolutely necessary to 
start a debate with the question Where is our problem? instead of debating 
only whether one specific technology is dangerous or not.  the history of 
science clearly indicates that you can discuss safety questions for years and 
years without coming to an end and rule out the famous rest risks.  When 
finding out what the real problem is for which a technical solution needs to 
be found (e.g. providing sufficient healthy and nutritious food), in a second 
stage different alternatives should be discussed to evaluate how they 
contribute to the solution of the problem.  In a third step, the potential 
hazards related to the most promising technology should be compared to 
the benefits gained when using it.  A fourth step would then be to evaluate 
the potential risks related to the second best option and compare the two 
risk potentials and the size of the damage in case the risk becomes a hazard.

	3.  For a responsible and serious evaluation of safety data as provided 
by companies or Competent Authorities, you need very specialised expertise - 
something which not every NGO can provide. The danger thus exists that the 
impression will arise that NGOs are in favour of a product, a process or a 
technology application because they do not have the appropriate questions when 
evaluating the product / process or technology due to limited expertise 
resources.

	4.  Participating NGOs need to have the feeling that their discussions 
can really change something.  It is, however, extremely unlikely that a 
company will declare that, in case the evaluation by the NGOs was not 
sufficient, the product would not, for example, be placed on the market. The 
question therefore arises as to what is the reason behind the whole discussion.
  It might be that the transparency, the fact that NGOs can check the 
authorisation files, is already something which should be seen as positive.  
It should, however, be clear right from the beginning what the goal or the 
scope of the whole debate is.  Clear recommendations concerning the 
deregulation of the EU Directives 90/219 or 90/220/EEC could be an example.

	5.  The evaluation of single products is extremely time and cost 
consuming whereas the political processes are usually working faster - so 
that it might be the case that NGOs are occupied by work which prevent them 
from acting at a political level because of limited resources.

	6.  The evaluation of single product is also usually too complex for a 
whole organisation to follow it.  Thus you have the difficulty that the 
scientific discussion will be carried out by one or two representative of the 
NGO whereas the results of the evaluation have to accepted by the whole 
organisation which will also be identified with the results of the process 
(and its discussion in the public media).  This makes it necessary to 
establish a continuous information transfer between the negotiator and the 
organisation itself.  If this is done seriously - and thats the only way it 
works - this is extremely time-consuming and will effectively block other 
activities of the organisation because most NGOs work is based on volunteers 
with limited resources.  This blocking is something an NGO cannot afford.

	7.  Because of the financial interests of the participating companies, 
the results of the discussions of a round table evaluating a product, a 
process or a technology can hardly be as open as they should be.  Although it 
should not always the ultimate goal to reach a consensus, this should at least 
aimed at.  If people are pushed too hard to find a consensus, however, the 
system will break down.  The rules of the dialogue (for example, concerning 
decision-making procedures, of confidentiality, of secretarial support, etc.) 
have to be clear right from the beginning to avoid a situation where one of 
the participating partners will form the impression that  administrative rules 
will be used to the advantage of another.

(JK)





REVISION OF DIRECTIVE 90/220/EEC is ON  COMMISSIONs AGENDA FOR LATE 1996

The deliberate release Directive 220 is one of the environmental issues on the 
list of tasks to be tackled by the Commission during the latter part of 1996.  
According to news item in the press, a report has been prepared on the 
functioning of the Directive which has been through inter-service consultation,
and a source close to Commissioner Bjerregaard was quoted as saying :  Its a 
critical report and will probably point to the need to revise the directive in 
1997, adding that most problems related to the time taken to process requests. 
 A proposal to extend to strategic planning decisions the requirement for 
environmental impact assessments (EIAs) is also underway.  Discussions at 
inter-service level have increased the consensus on this proposal so we stand 
a fair chance of getting this passed through the Commission source was 
reported as saying.

NGOs involved in the round table consultations with DG XI to discuss revision 
of Directive 220 - including FoEE - have received no feedback from the 
Commission, despite several requests, since the last meeting of the round 
table in February 1996.
 
(GL)


APPEAL FOR CONSERVATION & OPTIMAL UTILIZATION OF BIODIVERSITY & GENETIC 
RESOURCES FOR FOOD & AGRICULTURE 

On August 7, 1996 an appeal was launched in Rome by the Presidents of the 
Academies of Science of Italy and of India in preparation for the World Food 
Summit which will be convened by the Food and Agriculture Organization of the 
United Nations in Rome, Italy, from 13 to 17 November 1996.

In their opinion, biodiversity and genetic resources are crucial to ensure 
food security for the growing population of our planet.  Based on the major 
commitments of countries adopting the International Undertaking on Plant 
Genetic Resources, adopting the Convention on Biological Diversity (UNCED, 
Rio de Janeiro, June 1992), in establishing the FAO Global System for the 
Conservation and Utilization of Plan Genetic Resources for Food and 
Agriculture, and in approving the Global Plan of Action for the Conservation 
and Sustainable Utilization of Plant Genetic Resources for Food and 
Agriculture, the Appeal to Concerned Scientists throughout the World was 
initiated.  Their goal is to :

1.  Express the complete support for the objectives and aims of the World Food 
Summit being convened by the Food and Agriculture Organization of the United 
Nations in Rome, between 13 and 17 November 1996;

2.  Appeal to fellow scientists in all countries, particularly those with the 
responsibility of advising governments on biological diversity, and on the 
implementation of Article 10 of the Convention on Biological Diversity, which 
foresees the need to integrate consideration of the conservation and 
sustainable use of biological resources into national decision-making, to :

.  Join together in a strong movement of ideas to support the complete and 
expeditious application of the principles and rules of the Convention on 
Biological Diversity;
 
.  Express explicitly the willingness to put their knowledge and experience at 
the disposal of their fellow countrymen and women, their governments, and the 
United Nations, to strengthen the foundations of multilateral cooperation in 
this field, for the betterment of all peoples and the good of generations to 
come;
 
.  Work with governments, supranational and international agencies, the mass 
media and public opinion in general, to make a reality of the farsighted 
programmes initiated a long time ago by the United Nations and the Food and 
Agriculture Organization in favour of an equitable and sustainable use of 
biological diversity, which is the key element in the achievement of 
sustainable food and nutrition security;
 
.  Promote, in collaboration with national authorities in developing countries,
 and with scientific bodies and private industry :

.  the effective conservation in situ of wild relatives of crops and 
agricultural animals and the development of in situ gene parks;

.  dynamic on-farm conservation strategies which aim both at ensuring the 
long-term conservation of agricultural genetic diversity,and at the econmic 
and social development of the farmers themselves, and their farming commuities;

.  the secure conservation of resources by completing ex situ conditions, 
particularly of materials at risk, and also by bringing such collections to 
the International Network of ex situ collections under the auspices of FAO;

.  intensive evaluation of the immense reservoir of characteristics of 
agricultural genetic resources, for improving and extending utilization;

.  optimal utilization of agricultural genetic resources, through 
biotechnology in the service of the fundamental needs of humanity;

.	Ensure that farmers rights are regarded as fundamental rights and that 
their past and on-going contributions to genetic resources cooperation and 
enhancement are recognized and employed.

3.	Call for :

.	the full respect of the rights of the countries in which agricultural 
biodiversity is found, and of their farmers and farming communities, so as to 
avert the grave continuing danger of genetic erosion and the irreparable loss 
of these resources;

.	the rapid and effective completion of the revision of the International 
Undertaking and the strengthening of the FAO Global System for the 
Conservation and Utilization of Plant Genetic Resources, and the funding for 
the implementation of its Global Plan of Action;

.	the realization of Farmers Rights within the context of the revision of 
the International Undertaking, and the development of mechanisms for its 
implementation. The revised International Undertaking may then become a 
protocol of the Conventions on Biological Diversity.

4.	Stress that international, planetary cooperation is imperative without 
delay. If the danger is incumbent on all, the benefits of collaboration will 
also be for all.

To join the appeal to all governments please send your name, title, institution
, postal address, and e-mail address, before 5 November 1996, to:

.	Prof. Gian Tommaso Scarascia Mugnozza, Italian Academy of Sciences Villa 
Lontana, Via Cassia Antica, 35 00191 - Rome, Fax: 39-6-36300057, 
E-mail: gtsm. ias@unitus.it

.	M.S. Swaminathan, President National Academy of Agricultural Sciences 
and Chairman of M.S. Swaminathan Research Foundation-Madras, India.

(JK)


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Editor : Gill Lacroix, Contributors: Jens Katzek (JK), Gill Lacroix (GL), 
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