Comments on the project "Latin America capácity-building in biosafety GEF"

Comments on the project

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By Red for an A.L. Free of GMOs

The Network for a GMO-Free Latin America has read with great concern the project on biosafety training for Latin America of the World Bank and GEF, as it threatens the agricultural biodiversity of five crops that have a very great cultural and social importance, and four of them have their center of origin and diversity in the region.

The Network for a GMO-Free Latin America has read with great concern the project on biosafety training for Latin America of the World Bank and GEF, as it threatens the agricultural biodiversity of five crops that have a very great cultural and social importance, and four of them have their center of origin and diversity in the region.

The ultimate purpose of this project is to create the conditions for the commercial introduction of these crops in the region, through risk assessment methodologies and to develop work on the paradigm shift in civil society organizations, which opposes to the introduction of genetically modified organisms and in the perception of the general public, in the face of these new technologies.

We believe that given the project's implications for regional biodiversity, food sovereignty, and the social and cultural values ​​of the peoples living in the countries where the project is to be implemented, it should not be financed by the GEF. nor implemented.

Below is an analysis of the project

1. The project paradigm

The paradigm of the project is to strengthen regional technical capacity in countries that are centers of origin of biodiversity in the Andean region, Mesoamerica (and Brazil), using five crops (cassava, cotton, corn, potato and rice) as models to develop evaluations and risk management, and cost benefit analysis methodologies for new transgenic products, and maximizing economic scale, by exploiting comparative advantages in participating countries.

The selected countries are:
Brazil. In this country they will work with cassava, corn, potatoes, cotton and rice
Colombia: Yucca, potato, corn, cotton
Costa Rica: Rice
Mexico: Corn and cotton
Peru: Pope
CIAT: Cassava, corn, rice and cotton

It should be mentioned that cotton has two centers of origin in Latin America: The Andean region and Mesoamerica. In the Amazon there are also traditional varieties and wild relatives, and it is used for medicinal purposes among some traditional peoples.

Cassava is native to the Amazon and there are wild relatives and traditional varieties of these crops in Colombia, Brazil and Peru. The cultural importance of this crop is fundamental in the region, and is linked to the identity of the different Amazonian communities, particularly women.

The potato is native to the Andes, with a very high biodiversity and presence of wild relatives in Peru and to a lesser degree in Colombia. Potatoes are the most important crop in the Andean region and are associated not only with the food security of the peoples, but also with relations of reciprocity and the strengthening of the community social fabric.

Corn was domesticated in Mesoamerica, but its biological diversity is of great importance also in the Andean region and in Brazil. Corn is a sacred crop for many Mesoamerican and Andean peoples, and is a basic component in the diet of the region's populations.

Rice, although it is not a native crop of America, practically in all tropical and subtropical countries of Latin America, there is an important diversity of local varieties, developed especially by indigenous and peasant communities, which are adapted to the environmental and socioeconomic conditions of these countries and that are part of the important genetic heritage that local communities have.

This is a project that creates the technical and administrative conditions for the commercial income of these crops in these five countries, it will have a serious impact for the entire region (since the intention is that this experience is replicable to other countries, see Sustainability and Replicabity, p. 16), especially in countries where these crops have cultural, social and economic importance, since through international trade, gene flow and cultural practices, conventional crops could become genetically contaminated.

The project says that these crops have been chosen precisely because the centers of origin of these crops are located here, and because rice (whose center of origin in Asia) is a staple food in the region. The mere fact of trying to implement a project that deals with transgenic crops in centers of origin of these species, which are fundamental in world food and agriculture, should be a strong argument to reject it.

It is difficult to understand the logic by which the GEF finances a project that puts agricultural biodiversity at risk in several Latin American countries.

2. Project components

2.1. Strengthen technical capacity

It is proposed to strengthen the technical capacity in generating knowledge for risk assessment and management in the 5 participating countries, using the five crops mentioned.

As a result, it is expected to have standardized methods for risk assessment, risk mitigation, and emergency response mechanisms. In the majority of Latin American legislation, risk assessment is a prerequisite for the entry of transgenics, whether at an experimental or commercial level. These lines of work reveal that the long-term intention of the project is the introduction at the research and commercial level (see page 47) of transgenic crops in their centers of origin.

It has been the call of social organizations in Latin America that there is a total ban on the introduction of transgenic crops in their center of origin. This is a measure that has been adopted in other regions of the world, when the objective has been to protect traditional varieties and wild relatives (which, in addition to their cultural value, constitute the raw material for the improvement of modern varieties).

It is not a question of managing risk or knowing how to respond to emergencies, for example, in cases of genetic contamination, but rather of avoiding contamination, because genetic contamination is irreversible, and the contamination pathways are multiple, not only through flow of genes, but of contamination of seeds, of tubers (in the case of potatoes and cassava), of the emergence of volunteers, etc. And above all because of cultural practices that indigenous and peasant communities have in each of the countries where the project would be applied, and that have ensured the conservation and creation of agricultural biodiversity, such as experimenting with new seeds, bringing seeds from a region to another. another to exchange with relatives, friends, or to exchange them with other products. In the case of potatoes, farmers collect the tubers that remain in the ground after harvest, and if they are transgenic, they can enter the production chain unnoticed.

Once a transgenic variety is released in a country, it is impossible to stop genetic contamination. In a study by the Union of Concern Scientist (2004) [1], genetic contamination was reported in conventional corn, soybean and canola seeds with transgenes from genetically engineered varieties in the United States. The project attempts to validate perspectives to prevent or restrict gene flow, based on the available literature, even though practice shows that once in the field, paparring gene flow is impossible. It is interesting to mention that the project attempts to restrict gene flow, which simply means setting certain limits, but it does not address genetic contamination in the background.

There is enough literature that shows that there is introgression from cultivated varieties and their wild relatives in species such as corn, cassava, potato, among other crops [2].

The studies done by Quist and Chapela (2001) [3] in the State of Oaxaca - Mexico and later corroborated by the Commission for Environmental Cooperation of North America, shows that there is genetic contamination in traditional varieties in Mexico, despite that up to now it is not allowed to plant transgenic corn in that country, and that this has possibly occurred through the authorized importation of transgenic corn grains from the United States.

Scurrah et. to the. (2005) [4] demonstrate that there is gene flow from potato crops to their wild relatives in Peru [5].

Another expected result of the project is to have risk assessments and environmental risk management of the 5 crops, made from a risk / benefit perspective. What benefit can it mean to introduce transgenic plants to their center of origin where there are wild relatives of these species?

Regarding the monitoring of gene flow in the 5 crops, the proposal says that few large-scale studies have been done, but that it is possible to monitor transgenes at a commercial level (p. 47) using available methods. Are there methods for large-scale monitoring of transgenic crops in their center of origin, and in areas of such high diversity as Latin America? Are these methods applied to the specificities and cultural complexities of the countries where the project is to be implemented?

On the other hand, this statement shows (again) that the ultimate interest of the project is the release of these crops at a commercial level (in their center of origin).

The proposal adds that the methods are commercially available, and a footnote refers to a firm specializing in doing this type of work. The note says the company can test for almost all commercially released crops. However, here we are talking about crops that have not been released commercially, and with new characteristics.

Another aspect that the project addresses is related to the effects of transgenic crops on “non-target organisms”. These non-target organisms are important components of biodiversity. Let us remember that these countries have the highest levels of biodiversity in the world. Despite this, the objective of the project is only to minimize impacts. In the case of biodiversity centers, the only possible alternative is to avoid impacts.

2. 2. Socio-economic evaluation

Another objective of the project is to improve the understanding of the economic costs and benefits associated with the use of transgenic crops in tropical Latin America, and to improve the technical capacity of the countries of the region to make cost / benefit evaluations from the socio-economic point of view. . In this regard, the project refers to Article 26 of the Cartagena Protocol, which literally says:

"one. The Parties, when making a decision on importation…, may take into account… socio-economic considerations resulting from the effects of living modified organisms for the conservation and sustainable use of biological diversity, especially in relation to the value that diversity biological has for indigenous and local communities.

2. The Parties are encouraged to cooperate in the field of information exchange and research on the socio-economic effects of living modified organisms, especially on indigenous and local communities ”.

It is clear that this article refers to the value that biodiversity has in indigenous and local communities (in this case, potatoes, corn and cassava, but also cotton and rice).

Despite this, the project aims to “develop skills to analyze the potential costs and benefits of transgenics in centers of diversity, and build a baseline that can serve to monitor future progress, in the event of an expansion. of these transgenics in the selected countries ”. It is evident that the project is more oriented towards evaluating the potential benefits of transgenic crops, than the real impacts on the agricultural economies of the countries where the project would be implemented, and especially on the productive systems and food sovereignty of small farmers, who they are the vast majority in these countries.

As a methodology, they propose to adapt methods and instruments to evaluate the socio-economic impacts of the five crops in the selected countries.

The proposal says that "Some data used to evaluate the cost / benefit of GMOs are the same as those used to evaluate conventional agricultural technologies" and that little more data is required related to the environmental impacts of GMOs and consumer acceptance. . The way the bill interprets Article 26 of the Protocol is quite capricious. It is only concerned with the acceptance of consumers (possibly European), and not the value that the five crops have in the local communities and indigenous peoples of the region and the possible impacts of their introduction as transgenic.

And on the other hand, he affirms that the methods used to evaluate the impacts of transgenic crops are the same as those used in conventional agriculture, and then he intends that through this project “an adequate level of protection is ensured in the region to the introduction, manipulation, use and experimentation of transgenics in their centers of origin and in centers of diversity ”.

But perhaps the fundamental question that should be asked is: Are there methods to assess the socio-economic impacts of transgenic crops in their center of origin, and in regions where these crops have such an important cultural, ritual and spiritual value for the communities? local, as are the cases of potatoes, corn and cassava in the Andean, Mesoamerican and Amazon regions respectively?

Cost benefit analysis and risk assessment

It is necessary to refer to the type of analysis that you want to use: cost vs. benefit. This is a highly questioned method of analysis, as it only takes into account economic aspects, and is less and less used in the analysis of complex problems, such as the introduction of GM species in their centers of origin.

Multicriteria analysis, on the other hand, seeks to integrate the different dimensions of a reality in a single analysis framework to give a comprehensive vision and in this way have a better approach to reality. Multicriteria analysis is an adequate tool for making decisions that include social, economic and environmental conservation objectives, and also when a plurality of measurement scales converge (physical, monetary, qualitative, social, etc.).

Despite this, there are aspects related to the cultural, social and productive values ​​of the indigenous peasant farmers of the countries that intervene in the project, which cannot be quantified and valued solely with economic parameters and therefore risk assessments of the GM crops cannot be evaluated under the principles and methodologies outlined in the project.

Risk assessment, on the other hand, has also been quite questioned as a method to predict the impacts of transgenics on the natural environment and on local populations.

Risk assessment places too much faith in science to predict environmental damage, which in general is complex, without taking into account that many of them cannot be measured.

Take the case of the contamination of traditional varieties in southern Mexico. No risk assessment would have been able to scientifically predict that this would occur, and that is why the Mexican Government agreed to import transgenic corn for human consumption (and although it did not accept GM corn to be released into the environment). The risk assessments did not take into account the economic and cultural complexities of Mexican society, which resulted in such contamination.

Therefore, the effectiveness of risk assessment is limited by these gaps, creating large uncertainties and weakening the predictive power that science believes it has.

Although risk assessment is considered a scientific tool for making decisions; it is actually based on both scientific assumptions and political decisions, making the instrument subjective and not scientific.

A conventional risk assessment is based on some assumed concepts such as: "There is a capacity to introduce transgenic crops in their center of origin and diversity, without impact, if the risk can be managed."

Elimination of the risk is not considered in the risk assessment. It works to manage risk, not to eliminate or prevent it. In fact, the project talks about minimizing, restricting… the flow of genes, not avoiding genetic contamination.

Risk assessment is liable to produce a high degree of uncertainty. Arbitrary and pre-established assumptions are generally used, and extrapolations are made from similar or similar conditions. In the case of the analyzed project, it is intended to make extrapolations that conditions that are not even similar, and for this reason it is proposed to have as project partners agencies from the United States, Canada, Argentina and South Africa (See below). Or use methodologies developed for other social and environmental realities.

Risk assessment focuses on issues that can be quantifiable. It works with the concept such as how much pollution is acceptable ?, What problems are we willing to live with ?, and not how to prevent damage, or how to look for safer agronomic alternatives for the problems to be solved (in regional biodiversity there are many alternatives for selected crops).

2.3. Public awareness and communication on biosecurity

This is the third component of the project. Part of the presumption that the information that the public has in relation to genetically modified organisms is alarmist and is not based on science, and with this project it is intended to have a balanced view on GMOs.

In the different spaces for debate that take place in the five countries where this project will be implemented, those who defend transgenic crops limit themselves to describing the molecular techniques required to develop a GMO. There has been no real scientific debate on their part about biosecurity or the impacts of GMOs. Much less when it comes to introducing them in their centers of origin.

Those who have maintained the scientific debate based on the few studies that exist in the world on the impacts of GMOs at the level of biodiversity, human health, environment and socio-cultural aspects, have been the sectors that oppose the introduction of GMOs in the region, so the assertion made by the developers of the analyzed project (that the opinion of those who oppose GMOs is alarmist and not based on science) is basically not true.

In all five countries there have been very important social demonstrations against the introduction of GMOs. Thus, due to the lobbying of civil society organizations, a bill to promote Biotechnology (and that is mentioned in this proposal) has been paralyzed in the Peruvian Congress.

In Costa Rica there are at least two zones declared free of GMOs and a very strong citizen movement against GMOs.

In Mexico there is a very strong coalition against the contamination of native corn, and there are multiple actions from indigenous and peasant communities to defend corn against genetic contamination. The recent biosecurity law (the same one that is mentioned in the project), was approved with the majority rejection of the society, for which it was called "Monsanto Law".

In Colombia, civil society won a lawsuit that requires the environmental license process for the introduction of transgenic crops; But the government has ignored this ruling and issued a Decree that creates the conditions for the approval of transgenic crops in the country, a rule that has been strongly questioned by many sectors of society. Similarly, in the Caribbean region, where there is a great diversity of native maize and a strong indigenous culture around maize, these indigenous populations declared their territory free of transgenics.

Brazilian society, on the other hand, is totally polarized around the issue of transgenics. The agribusiness group defends an agriculture based on GMOs, as peasant organizations linked to the Movement of the Landless, the Movement of Small Farmers, etc. (for whom Article 26 of the Biosafety Protocol was drawn up), are opposed to it.

At the recent Meeting of the Parties to the Cartagena Protocol that took place in Curitiba, Brazil in March 2006, social movements from around the world, but especially from Brazil, were able to influence governments to maintain the moratorium on technologies "Terminator". They also managed to get the Brazilian government to change its position in relation to the documentation that must accompany the importation of transgenics.

The project aims to create a paradigm shift in public debate by linking biosafety with biotechnology in each public space that can be accessed. It is intended to achieve this goal through messages "based on science and not on alarmist public discourse."

In a word, what you want to achieve is a public acceptance of the introduction of transgenic crops in their centers of origin and biodiversity.

Let us relate this component of the project with the analysis that is made of the possible risks that its implementation may face. These include the risk that there will be electoral changes in some of the participating countries, and that the new government rejects biotechnology. In this case, it is proposed to carry out a process of "education" to the new administration on the project and the methodologies.

3. Other aspects

3.1. Civil liability and compensation

In some way, the project foresees that it may generate, in the long term, impacts that involve aspects of civil liability and compensation, because the risks of the project include the fact that the Cartagena Protocol is being negotiated, and it must be adopted for 2008, a civil liability and compensation regime.

3.2. Safeguard measures

The proposal (in its Annex 10) maintains that since the objective of the project is not to plant transgenic crops, the safeguard measures related to environmental evaluation are not applied, despite the fact that in the long term, the result of this project will create the conditions in participating countries, to introduce transgenics in their centers of origin.

Nor does it consider that safeguards related to indigenous peoples' policies should be considered, despite the fact that we are talking about crops of great cultural, ritual and spiritual importance for indigenous peoples, such as potatoes for the Andean peoples, cassava for the Amazonian peoples and corn for Mesoamerica and the Andean region. Nor are safeguards related to pest management considered, despite the fact that one of the main characteristics introduced in transgenic crops is related to the issue of pest management, which has led to an increase in the use of pesticides (Benbrook, 2004) [6.7].

3.3. Other project partners

The project proposes to incorporate other partners that could contribute to the development of the project. From their specificities, all of them promote the commercial introduction of transgenic crops. These include:

Public Research & Regulation Initiative (PRRI), which was the only organization that, during the negotiations of the VIII Conference of the Parties to the Biodiversity Agreement (Curitiba - Brazil), that took the floor to defend genetic restriction technologies, more commonly known as Terminator Technologies. This, despite the fact that more than 10,000 representatives of peasant and indigenous organizations from Latin America, particularly from Brazil, one of the participating countries in this project, spoke out against the possibility of accepting these crops based on analysis risk case by case.

AgBIOS: is a private Canadian company that advises commercial companies seeking approval to introduce biotechnological products, and that works with other public and private sectors seeking clarification on issues associated with the development and use of biotechnological products and processes. They also work on policy development and regulation of new transgenic foods, crops and trees. It does not work in the field of biosafety, that is, in avoiding the risks arising from genetic engineering.

AfricaBIO is an organization created by the private biotechnology company, to promote transgenic crops in Africa.

It is also proposed to include public organizations from countries that have not even signed the Cartagena Protocol (although the purpose of the project is the implementation of the Protocol), and that, through the so-called Miami Group, hindered the negotiation of this international protocol [8 ].

These organizations include the FDA, which is the agency that regulates the approval of new transgenic foods in the United States. In a study done on the regulatory system of transgenic foods in the United States, it reveals that the analyzes are made based on information from the companies themselves [9]. In early June 2006, the FDA received a lawsuit from a consumer group (The Center for Food Safety) to force the United States government to carry out a review of all approved GMO foods, and the labeling thereof. They ask that the process must be done under a rigorous scientific process, since until now the approval of new foods has not been evaluated in a scientific way [10].

APHIS is the service of the United States Department of Agriculture in charge of the inspection of plant and animal health. In 1987 APHIS established an inadequate monitoring system for GMOs that are going to be evaluated in the field, but which later evolved into a deregulation system. In 1993, it announced that certain crops would be allowed to be planted without a permit, and required simply a notification, including: corn, cotton, potatoes, soybeans, tobacco, and tomatoes, as well as any additional species determined to be able to be introduced in a way safe. In 1995, 87% of field tests were done with a simplified format, and the goal was that 99% of field studies be done through notification only. Between 1987 and 2004, APHIS had received 11,090 applications to release genetically modified crops into the environment. Of these, 10,296 had been approved, allowing 18,608 releases to the field at 47,219 sites [11]. APHIS is an agency that facilitates field testing of genetically modified organisms, and here we are talking about avoiding risks of introduction of crops in their center of origin, not about facilitating their entry, which is the input that APHIS could provide in the draft. In a recent study by the Center for Food Safety, it found that the regulations that APHIS works with are inadequate to control gene flow from cultivated varieties to their wild relatives [12].

The EPA is the United States environmental protection agency, and regulates insecticidal transgenic plants (such as cotton and Bt corn). The EPA does not collect its own data on the potential health impacts of transgenic crops that it approves and accepts the analyzes made by companies, with very poor scientific standards. EPA has ignored the evidence of independent researchers when this evidence comes into conflict with the interests of companies. EPA raised the allowable levels of pesticide residues on crops to facilitate the introduction of herbicide-tolerant GMOs [13].

USAID has served to promote the North American agenda to expand GMOs in Africa and other continents [14].


Latin America is the region with the greatest agricultural biodiversity on the planet. This biodiversity corresponds to a cultural biodiversity that is made up of indigenous peoples and peasant communities that have conserved, recreated and used this biodiversity, and maintain a very special spiritual relationship with it.

Corn, potatoes and cassava are very important crops for the Mesoamerican, Andean and Amazonian communities. La introducción de variedades genéticamente modificadas de estos cultivos en la región, puede tener impactos socio económicos, culturales y sociales de muy graves, especialmente entre las comunidades y pueblos indígenas ligados a la biodiversidad.

El arroz es también un cultivo de gran importancia regional, pues constituye parte de la dieta básica de esas comunidades.

El proyecto GEF que se está analizando, tiene como objetivo a largo plazo, facilitar la introducción de variedades transgénicas con fines comerciales y de experimentación justamente de los cultivos más importantes para las comunidades indígenas y locales de los países en los que se implementaría el mismo.

Este proyecto tendría también impactos negativos sobre la biodiversidad regional, pues el proyecto facilitaría el ingreso de cultivos transgénicos en sus centros de origen. La contaminación genética de las variedades criollas y de los parientes silvestres de los cultivos, pondría en riesgos dichos cultivos porque tanto las variedades tradicionales como los parientes silvestres de los cultivos, han servido para programas de mejoramiento.

Dado que la intención es que esta experiencia sea replicable a otros países, este proyecto puede tener un impacto grave para toda la región, especialmente en los países donde estos cultivos tienen importancia cultural, social y económica, puesto que los cultivos convencionales podrían contaminarse genéticamente, a través del comercio internacional de productos agrícolas, del flujo de genes y de prácticas tradicionales (como llevar semillas de un país a otro).

Un resultado final de este proyecto puede ser que las comunidades campesinas e indígenas, se queden sin alternativas y tengan que recurrir a semillas transgénicas patentadas, que pagar regalías, y aumentar su dependencia a las empresas transnacionales.

Por estas consideraciones, y otras que han sido analizadas en este documento, consideramos que este proyecto no puede ser financiado ni implementado.

1. Union of Concerned Scientists. 2004. Gone to the Seed. Transgenic Contamination in the Tradicional Seed Suply.
2. Jarvis, Devra I. and Toby Hodgkin. 1999. Wild relatives and crop cultivars: detecting natural introgression and farmer selection of new genetic combinations in agro-ecosystem.. Molecular Ecology 8, S159-S173.
3. Quist & Chapela. 2001. Transgenic DNA introgressed into tradicional maize landraces in Oaxaca, Mexico. Neura. Vol. 414, 29 November 2001.
4. M. Scurrah, S. Chumbiauca, A. Salas, R. Canto, J. Arcos, C. Celis, R. Visser, S. Cowgill, H. Atkinson. 2005. Dinámica de flujo de genes en el cultivo de papa y sus parientes silvestres en el Perú. El caso: variedades transgénicas con resistencia a nematodos. Séptimo Congreso Nacional de la RAAA, Arequipa
5…Ver también Humán, Z. Panorama de los transgénicos en el Perú. Posibles efectos en la Biodiversidad. Ponencia presentada en el Seminario “Impactos de los transgénicos en la agricultura sostenible” Arequipa noviembre 2005.
6. Benbrook, C,M. Genetically Engineered Crops and Pesticide Use in the United States: The First Nine Years. BioTech InfoNet Technical Paper Number 7.
7. Benbook, C. N. Rust, Resistance, Rum Down Soils, and Rising Cost – Problems Facing Soybean Producers in Argentina. Technical Paper No. 8
8. Se incluye organizaciones públicas de Estados Unidos, Canadá y Argentina, los tres países forman parte del Grupo de Miami, y ninguno de los tres han ratificado el Protocolo de Cartagena.
9. “Safety Testing and Regulation of Genetically Engineered Foods”??By William Freese & David Schuber. Biotechnology and Genetic Engineering Reviews
10. Reuters. Friday, June 09, 2006
11. TexPIRG. 2005 Raising Risk. Field Testing of Genetically Engineered Crops in the United States .
12. Gurian-Sherman, D. 2006. Contaminating the Wild? Gene Flow from Experimental Field Trials of Genetically Engineered Crops to Related Wild Plants. Centre for Food Safety. Washington D.C.
13. Biotechnology and Genetic Engineering Reviews
14. Una revisión completa del tema se puede encontrar en GRAIN. USAID in Africa: “For the American Corporations” Seedling No. 20.

Publicado en Semillas –

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