To : The Chair and Delegates of the Second FAO-WHO Global Forum of Food Safety Regulators
Re : Request for the consideration of proposals of consumer organizations and its network

I/we/my organisation has studied and followed the issues of the impacts of GM food and crops for years. We have found that until now no genetically modified organism has been certified as safe by any individual state or private agencies responsible for studies on their long-term impacts on health and environment.

Risk assessments under a framework which focuses on the principle of “substantial equivalence” between GM foods and natural foods have been strongly opposed by scientists because only the main nutrients of foods are assessed. They contended these studies have many weaknesses, especially in terms of its credibility. These studies only answer to the “intended” results while all the possible impacts are still not known. No strict measures are put in place and no follow ups on the impacts on consumers’ health and the environment in the long run are being done. Consumers all over the world have tried to appeal for their rights and demand for labeling but their voices are ignored.

While the sensitive issue of risk assessment process on GMOs remains unclear, multinational companies have already started conducting their GMO field experiments in many countries including South Africa, arguing that the experiments are done for the sake of consumers’ health and the environment. However, the process itself is full of flaws and not transparent. For example, in 199, in Thailand,  BT cotton spread out and contaminated other farms in the same area and in July 2004 GM papaya spread out of Tha Phra research station and contaminated nearby plantations in Khon Khaen province. Follow-up reports from works of our organizations and network, states that GM papayas are also found in Ubolrachatanee province and are likely to be found in other provinces as well. This has led to the conclusion that risk assessments undertaken by the food industry and state agencies themselves can not draw trust from the public.

All types of risk assessments on all forms of genetically modified living things have been continuously criticized on its principles, processes, and transparency by academics, scientists, environmentalists, consumer groups, farmers, and even political parties. Therefore, conflicts and the lack of acceptance among parties have also become clearer to the public.

Because of all these weaknesses, I/we thus propose and demand the following;

1. The support for precautionary principle. Food safety is a public health issue. If science can not assess the possible risks accurately, precautionary principle should be applied. All governments should suspend and prohibit all experiments on GM crops, and ban all imports of GM seeds/products in order to protect the environment from contaminations caused by GMOs, conserve organic production area, and protect farmers’ rights on the use of local plants. There is also the need to protect food producers’ rights to use non-GMOs raw materials, and protect consumers’ rights to safe food.

2. More transparent and more independent risk assessment processes. All underlying factors should be considered and a follow up mechanism on the environment and health impacts should be developed. Disadvantages and losses whether they are economical, social, or genetic should be assessed carefully.

3. Laws to enforce adequate labelling of all GM products. The labels must be clear, easy to read with distinctive features from other products and with information for traceability.

4. Laws on responsibility and liability. Producers should be held liable for environmental or health damage that may cause by GM products and foods with GM ingredients.

5. Laws to protect biodiversity with a mechanism to penalize those who allow GM seeds and GM crops to contaminate the environment while the risk assessment process is still on-going.




Thank you for your kind considerations.