April 14, 2010

Prof. Atanas Atanassov
President
Black Sea Biotechnology Association
Director
Bulgarian Joint Genomic Center 

Recently the Environmental Commission of the Bulgarian Parliament voted a 5-years moratorium on deliberate release into the environment and cultivation of GMOs. The motives for the moratorium were to reflect the public reservations.

A careful review of the moratorium reveals the following: the ban on cultivation of GMO (with commercial purposes) practically bans something that does not exist. Only one hybrid of GM maize – MON 810 is permitted for cultivation in the EU. MON 810 is modified for resistance to corn borer – a pest which could not be considered as a major problem for Bulgaria. MON 810 hybrid is also not consistent with the climatic and soil conditions in the country which means that it is not of an interest for the Bulgarian farmers. Having in mind the slow and difficult procedure for placing on the market of GMOs, especially for cultivation, it could not be expected that a diversity of GM varieties for cultivation will appear on the EU market. That means that except populist, the ban for cultivation will have no other result.

Things turn out to be different when it comes to the ban for deliberate release of GMOs into the environment. That will lead to a concrete result – termination of scientific research in Bulgaria, as a continuation of the non-working procedure for issuing of permits for deliberate release, foreseen in the current Law on GMO. No matter if the parliamentarians are aware or not, deliberate release into the environment (for purposes other then placing on the market, i.e. with non-commercial purposes) means field trials. Trials, normally performed by scientists as a natural extension of the laboratory work, is the only possible way to finalize the results of their scientific work. Trials are the tool for looking for the answers to questions like: what are the right isolation distances to guarantee GMO presence in conventional and organic production below the threshold, what is the possible impact of a certain GMO on the specific ecosystem of Bulgaria, how can we protect the environment and biodiversity, what are the correct labelling thresholds for seeds, etc.

The moratorium on deliberate release into the environment is a unique Bulgarian decision. Other member-states like France and Germany, for example (with or without real scientific data) have introduced a ban under the safeguard clause foreseen in Art. 23 of the EU Directive for a concrete GMO – maize MON 810. These countries, having in mind the importance of science development, are still authorizing field trials of GMOs. In that way on the one hand, at least pro forma, they meet the requirements of the EU legislation and on the other hand, by following the public perceptions, do not stand against the development of their own country. At the same time these countries have transposed the EU directives correctly that will avoid infringement procedure and possible financial sanctions.

What is the situation in Bulgaria? Bulgaria imposes moratorium (general ban) on deliberate release and cultivation of GMO without even trying to follow the requirements of the EU legislation. Even more, the draft Law amending the Law on GMO voted by the Environmental Commission of the Parliament does not fix the discrepancies with the EU Directives but even makes things worse. The new law keeps the general ban for deliberate release of GMO in protected areas and buffer zones of 30 km around them. Additional buffer zones of 10 km from apiaries and 7 km from fields with organic production are foreseen. The isolation distances for deliberate release and cultivation, included in Annex II of the Law, were additionally increased. An obligation is also envisaged for the Minister of agriculture to activate the safeguard clause under Art. 23 of the Directive 2001/18 when another Member-state has imposed a temporary ban on a GMO under the same provision, as well as when it comes to a number of species defined as traditional and economically important for Bulgaria (tobacco, vine, cotton, damask rose, wheat, and all vegetable and orchard crops). This could be defined as another approach for setting of a general ban, which implementation is not bound with presentation of new or additional scientific data, as it is required by Art. 23 of the Directive.

At the same time the main issue raised by public opinion – GM food and feed, was left out of the discussion. The moratorium has a reflection on research experiments and testing of GMO. The regime of placing on the market of GM food and feed is not affected. There is no way this regime to be affected having in mind that the Bulgarian market is part of the Common European market with free movement of goods. The only way to answer the public concerns – by guaranteeing informed choice for consumers, is entirely neglected. The real necessity is for a strict control on labelling of GM food, a complete intolerance of unauthorized GM food and feed, a clear definition of the competent authorities and their obligations and provision of complete and reliable information for the public.

The simple recapitulation shows that the conducted discussions and imposed efforts did not lead to a real progress, but rather to an opposite result. The issue of compatibility of the Bulgarian legislation with the EU requirements is left unsolved due to the inconsistency in the transposition process. A decision for imposing of a 5 years general ban on GMO was taken in complete contradiction with the basic principles of the EU law. Bulgaria is running the risk of an infringement procedure and possible financial sanctions. Even more, no progress was made for better functioning of the GMO control and for providing free choice for consumers.

What makes Bulgaria more amazing than other European member countries is that after 20 years transition period, the anti-GMO propaganda was the first case where an anti-GMO consensus was developed among the political parties, Parliament and the President. None of these were capable to see the realities and to avoid the mistakes of the old member countries made in the period 1998-2008.

What are the facts:

• Unbelievable speculation is that we eat transgenic tomato with fish gene(s), apple, carrot, etc. So far commercially available in Europe are soybean, maize, rapeseed and cotton which are imported as a feed, food and fiber. The only commercially cultivated plant in EC is the corn variety MON810 resistant to European corn borer.
• According to the European Food Safety Authority (EFSA) the present GMO products for food and feed are safe for human and animal consumption.
• EC including Bulgaria is not cultivating but importing more than 37 transgenic products form soybean, corn, and rapeseed. Most of them are used to feed animal stockbreeding. We eat milk, meat and eggs from these animals. No one animal is reported to suffer so far after eating soybean meal. We are dressed with transgenic cotton clothes produced in China and India. The same is with Euro banknotes.
• Europe is net importer, not exporter of the soybean and soybean products. What are the alternatives of soybean products to be replaced as a protein source in EC and particularly Bulgaria? There is no definite answer to this important question.
• What will happen if environmental disasters diminish the soybean production in the above mentioned countries, or it goes for a biodiesel production? The prices will jump but probably much more than the agricultural price spikes in 2007/2008.
• Another five years moratorium for GMO in Bulgaria for not testing and cultivation any GM plants will totally not only limit but will isolate the Bulgarian research from both the European and international cooperation in this area. There will be no enough educated and trained scientists who could not only examine the environmental and human health effect of the transgenic crops but also to advise the governmental authorities what to do.
• New more powerful technologies like various ~omics (genomics, proteomics and metabolomics) nanotechnology, “synthetic” biology (new small artificial organisms will be soon constructed) are entering quickly in our life and make GMO even “old technology”. They definitely will show much better what is the potential of the existing GMO products and will help to understand where and how we should apply GMO technology if it is necessary. Such knowledge will help us to understand the capacity of the living organisms and thus to increase the added value e.g. the cost efficiency of those used as a traditional (organic, ecological) and the biotech products.
• The technologies old or new should be never opposed each other and should be never banned. They have to be combined and regulated very properly locally and internationally.
• Interestingly enough there is no such opposition against the large scale application of GMO derived enzymes and peptides utilized efficiently in the food industry (meat, milk, wine, beer, confectionery, etc) and the pharmaceutical industry which application surpasses 75% and 30% respectively of the total production in the world.
• The big important crucial question here is how the big rich countries and the big multinational companies could help the smaller and poorer e.g. how not only the products but technologies to reach them. How some products could be developed by cooperation where the multinationals could not only be a seller but could develop partnership for example in smaller crops for every region in the world. As a result such products could be mutually shared intellectually.
• Another big question is how the current regulatory situation could be improved in order public research in the smaller or developing countries could reach the realization of the R&D investment. For example, the AgroBioInstitute in Bulgaria has more than 30 pre-commercially developed GMO lines from potato, tomato, tobacco and alfalfa which are in the freezer.
• Even if there is no GMO ban, the severe restriction of the regulation (risk assessment studies, the patenting or/and licenses) will not allow the independent commercial utilization of such products.
• The scientific opinion about GMO application with a few exceptions is ignored in any level – politicians, media, NGOs, etc. Bulgaria is not an exception. The second paradox here is that ABI as a leading institution in Bulgaria and in the region recognized as a first Center of Excellence from EC in 1999 among all the accession countries and among all the disciplines is not seen at all by its own government.
• During the last 20 years from net exporter Bulgaria became a net importer of food and feed. In order Bulgaria to boost again its food and feed production (it is one of the most naturally rich countries in the world in regard of the agriculture) require to use properly any new technologies which means efficient utilization of land (no till farming), water (drop irrigation), of fertilizers and pesticides. It also means that both GMO and organic farming technologies could be used in parallel. The first one could be applied for the field crops (corn, rapeseed and cotton at present time) and all the rest as grape, roses, small fruits, pasture, herbs, mushrooms, etc. as an organic farming. Here the public bodies and institutions can help to overcome resistance and GM crops may be more acceptable if they come from government institutions and not only from big companies.
• In 20 to 30 years the climate change will change the market and the trade. The food price trauma in 2007/2008 is telling that the farming needs to be as efficient as possible. In the year 2025-2030 the agricultural industry will be an industry number one. It will determine all the other industries – as food and feed, textile, pharmaceutical, bioenergy, etc. Investing in agricultural technologies means future social security, environments stability and an economical progress; rejecting the agricultural technologies like GMOs and the others would be a disaster.

Website: http://www.bsbanet.org

Published: April 14, 2010