A genetically modified plant. A complex ecological environment. This interaction could provide a base for meaningful scientific investigation or a recipe for generating data having little relevance. A sober view tells us that GM crops are inherently neither good nor bad, but it is their application in farming systems that have impacts, as is the case with conventional crops. All agriculture have had ecological impacts since the first planet dweller starting making holes in the soil to plant seeds. In modern times, overpopulation, urbanization, industrial revolutions, warfare and poor political decisions have had more negative environmental impacts than agriculture.

It is a good sign that members of society express criticism on human activities that may impair sustainability of future generations, even if such members are self-appointed whistle blowers. It is also good that such concerns may lead to domestic policies and international agreements to curtail damage. However, eventually the solutions lie in science-based decisions and not in emotional rhetoric. The Convention on Biological Diversity and the Cartagena Protocol on Biosafety have noble intentions but the Protocol-signed and entered into force with major articles still open to debilitating cycles of negotiation-contains vague elements like precautionary approach and sustainability, subject to divergent interpretations. Only time will tell whether the CBD and the CPB attained their objectives or whether they have impeded beneficiation of biodiversity and benefit sharing, and obstructed international trade. (Some cynics may hold the view that the Protocol has become a forum for perpetuating jobs and globe trotting).

The South African GMO Act of 1997 is very comprehensive and overarching, applies to genetic modification of all organisms, and has served to maintain a balanced approach: providing a framework for ensuring safety while facilitating modern biotech R & D and application. Its requirements have been regularly updated and the act amended in 2006 to comply fully with the Protocol. The Department of Environment and Tourism has since also cranked out a wide range of new laws with good intentions but doubtful capacity to enforce. One facet deals with Environmental Impact Assessments (EIA) applicable to GMOs. It is also disturbing that much use is being made by this department of contracted external environmental lawyers and rather few expert biotechnologists, although opportunities have been created for inputs by all.

The whole issue of EIA and ecological impact, however well intended, present a range of pitfalls that South Africa probably shares with many other countries.

The strength of the GMO Act of one-door, one-key joint decision making on a consensus basis by its GMO executive council representing eight government departments, is being undermined by Environment mostly voting against approval of applications.

The perception seems to persist that GM crops inherently are risky and need to be stringently regulated, ignoring the fact that all present environmental problems are due to conventional species and socio-economic factors. In fact, the GMO Act is more comprehensive than legislation on uranium mining or handling hazardous nuclear waste.

Inadequate attention is being given to proven and potential positive ecological impact. Biotech applicants, in submitting applications, may also fail by focusing on responding to concerns and less on stating benefits.

It seems that inadequate attention is being given to negative impacts (socio-economic and ecological) that result from denying a new technology.

Ecological impact considerations should feature from the permit application stage through to post-release monitoring stage. It is here that ecologists and biotechnologists run into a brick wall, the former seldom admitting that. Firstly, experts agree that, especially in South Africa, we have very limited understanding or credible data on the extreme complexity of ecological systems that have a multitude of variables with ongoing dynamic interactions over time and over sites. Secondly, one cannot evaluate impact without a benchmark. Since neither conventional variety releases nor organic or conventional farming require EIA and since we have a paucity of ecological data on farming systems, there exists no benchmark. Thirdly, there is no clarity on what is essential to know and what is nice to know. Fourthly, a regulatory requirement needs to be considered in the light of what is attainable and affordable.

Some scientists, especially academics, may sometimes be their own worst enemy by supporting a demand for an open-ended, unclear EIA, envisaging that funding for project studies will be forthcoming and that this will lead to pushing more graduates through college and generating more scientific papers. The focal issue should be to how to ensure pre- and post-release workable biosafety of new GM crops, not academic agendas. It has now become apparent in very recent times that the Department of Environment may move to a more realistic, science-based approach on EIA.

In conclusion, South Africa approved the first GM cotton trials in 1990 and the status of GM crops in 2006/7 reached almost 50 percent of maize area, 75 percent of soybean and 93 percent of cotton, and there are four regional biotechnology innovation centers supported by government. No invasive plants, no super weeds, and no damage to the environment, human and animal health have been documented over 17 years. The country, as for other developing countries, should maintain a balanced scientific approach and not permit a good regulatory system to go off on a tangent that will preclude access to international biotechnologies and obstruct development of national biotechnologies. It is incumbent upon scientists to join forces through their technical associations and participate in government regulatory developments, also serving as watchdogs to ensure that good intentions are not derailed. To date, only a negligible portion of scientists engage in lobbying.

Note: The author was member of the government working group that drafted the GMO Act and is still involved in making inputs into amendments, while monitoring functioning of the system. Dr. Wynand van der Walt can be reached at wynandjvdw@telkomsa.net.