Ongoing national concerns: consuming GMOs without consultation and changing policy spaces
The ZAAB (Zambia Alliance for Agroecology and Biodiversity) has been engaging with the NBA and governing ministry regarding GMOs since 2010. Major concerns at the time were: unregulated and unlabelled imported food containing GMOs; the lack of institutional capacity and funding to adequately address the wide range of issues and challenges related to modern biotechnology use; and the increasing foreign lobby push for Zambia to change its non-GMO position.
The NBA have worked hard to better regulate imported processed foods containing GMOs and enhance public communication. Given the difficult economic constraints as a publically funded agency, we applaud and are grateful for their concerted efforts.
There are two broader issues that the ZAAB remains concerned about. These have not been addressed properly, nor is the public adequately aware.
Our concerns relate to the two different aspects of GMO governance in Zambia:
1) The importation of processed GMO food products
2) The ongoing policy amendments to change the country position on production of LIVE GMO crops.
We deal with the first issue: The importation of processed GMO food products and the limitation to public participation
The NBA are working hard to ensure food products are regulated and go through the correct licensing processes.
The ability of the public to object to these imported products, as per their legislated rights, is however extremely constrained. In order for citizens to participate in the pubic consultation process and object to GMO food imports, they must physically visit the NBA offices in Lusaka, and are then allowed to view only the non-confidential elements of the application dossier. The application details may not be copied electronically or distributed to those not in the capital city. Objections based on scientific analysis, submitted within the 30 day window, are then considered by the NBA scientific advisory board.
The admired position and legacy of Late president Mwanawasa was that all citizens, and the nation as a whole, have a right to be protected and fully engage in GMO decision making processes. This was not limited to those privileged and able to compile scientific objections. It also included consumers concerned about social, economic, cultural and ethical issues. It considered market gaps, or opportunities to instead protect Zambia’s market and enhance value addition and support local livelihoods.
For importers to simply publish an advert in two newspapers and submit an application dossier to the NBA offices – that is only accessible to an elite minority in Lusaka – does not constitute public consultation. This argument is backed up by the fact that the NBA has never received a scientifically considered objection to an application. Given public opinion, the lack of objections does not reflect the wishes of the Zambia public. It instead reflects the inaccessibility and limitations of the public consultation process.
Many citizens have recently been horrified to find out that GMO processed products are entering Zambia and that the ACT actually facilitates this. The public have a right to a broad and accessible consultation process, to effectively engage in decision making on GMO products. If public consultation processes cannot be duly filled, then perhaps the products should not be imported and Zambia’s non-GMO market protected and local diversified production and processes supported instead?
The second issue we raise relates to: The ongoing policy review processes and national concerns, that are unaddressed by the Ministry of Higher Education and related authorities
In September 2017, the NBA/MoHE held an exclusive initial consultation process on a new draft of the national biosafety policy, in collaboration with COMESA and NEPAD. In December 2018, another exclusive meeting was held, in collaboration with Gates funded African Biodiversity Network of Experts (ABNE), to develop regulations for the release of LIVE GMOs in Zambia. I.E. the production of GMO crops. ZAAB fully appreciates that ministries update policies from time to time and that stakeholders have been promised national consultation on this matter.
HOWEVER, if the Ministry of Higher Education and the NBA are indeed neutral in their policy position, then why are they allowing pro-GMO institutions to help craft Zambia’s new national policy and regulations – that in draft are written to favour the promotion, of GMOs? The ABNE is funded by the Gates foundation that has spent millions of dollars trying to develop GM crops and smooth the regulatory environment for the introduction of GMOs across Africa. The ABNE may be the advisory body to the Africa Union, of which Zambia is a part, but this does not mean that as citizens we should just accept their role in writing national policies that are meant to protect and uphold sovereign interest.
The NBA has shot back at ZAAB and other CSOs for objecting to the ABNE and Gates influence in national policy development, arguing that it made economic sense to use experts available to it through the continental body, despite their well-known pro-GMO position. We remain opposed to this biased interference in national legislation drafting.
If the Ministry of Higher Education does not have the financial resources to draw on local expertise to craft its policy documents, then it does not have the financial resources to manage live production, adequate nation-wide testing, control export and imports, or contamination of seed and local food systems. It cannot deal with long term ecological, social and health impacts; loss of biodiversity, further malnutrition and soil infertility. It certainly does not have financial resources to compensate the economic opportunity costs of changing Zambia’s advantageous NO-GMO position.
The primary element within the current National Biosafety Policy of 2003, is its basis on the precautionary principle, and directive for strong liability and redress. These are the two major aspects of the national legislation that will be weakened if amendments are approved. Until then, GMO producers (biotech industry) will not apply for license in Zambia, because they do not want to be held accountable for the negative consequences or contamination arising from their technology. Industry have made this clear and hence why they want policy changed.
The ABNE is a key service provider within the Programme for Biosafety Systems and the Agriculture Biosafety Support Project, launched by the United States to fight back against the strong precautionary stance taken by African countries in the development of the Cartagena Protocol (something that Zambia proudly stood by). These high profile projects of the US aim to align African and Asian policy environments with the USA goals: the widespread adoption and acceptance of GM food from the US, enabling dumping of GM food onto local markets and control of African agriculture production. The International Services for the Acquisition of Agriculture-biotech Applications (ISAAA), recently quoted in media and known for their unsubstantiated statistics to boast of adoption of GMOs around the world, are part of this same US backed project, funded also by private sector itself.
ZAAB wants policy makers to recall where Zambia’s GMO history comes from. As far as the people of Zambia are concerned, Zambia remains a NO-GMO country. The NBA mentioned that this was the ‘old position’. For this position to change though, requires the citizens of Zambia to firstly, demand for this change. It is not for multinational seed and agrochemical companies or pro-GMO policy lobby bodies to enable this change.
ZAAB appreciates that the NBA are working hard to increase public communication mechanisms despite minimal public funding. We recognise that the MoHE has assured the public of consultation prior to policy changes; and applaud decision makers working to ensure this happens in a genuine manner. However, we remain with extremely concerned citizens who ask why given economic constraints, the Ministry is going ahead with developing regulations that will fundamentally change Zambia’s GMO position, and accepting support from pro-GMO policy lobby groups in the policy re-drafting phases. It is well documented that global GM crop production has primarily benefited transnational corporations and the wealthy, rather than the poor and hungry of the world.
We again appeal to the Ministry of Higher Education, the NBA and related decision makers to uphold the best interests of Zambia’s people, as well as its economy; to implement commitments to diversify the agriculture sector and enable the realisation human rights for all.
‘Modern Biotechnology’ and the resultant Genetically Modified Organism (GMO) are defined as different to ‘Conventional Biotechnology’ or traditional breeding, as the application of the “Fusion of cells beyond the taxonomic family, that overcome natural physiological reproductive or recombination barriers and that are not techniques used in traditional breeding and selection” (IAASTD, 2008).