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ZIMBABWE

[03 October 2006]

[SUBMISSION:ENGLISH]

SUBMISSIONS FROM ORGANIZATIONS

BRAZILIAN BIOSAFETY ASSOCIATION

[23 August 2006]

[SUBMISSION:ENGLISH]

BRAZILIAN SOCIETY OF PLANT BREEDING

[17 August 2006]

[SUBMISSION: ENGLISH]

To develop those answers an internal survey was run amongst the SBMP members working with biosafety and/or biotechnology in Brazil
1. Does your country have any plantations, either commercial or experimental, of genetically modified trees?

Yes. Brazil has only experimental plantations of GM trees. The species that are being tested are Eucalyptus and Papaya.

2. Has your country developed any platform/discussion forum/national committee etc. dealing with genetically modified trees?

Yes. Brazil has a governmental national committee, entitled "National Biosafety Technical Commission" - CTNBio. This committee gives technical support to the Brazilian Federal Government in order to update and apply the National Policy of Genetically Modified Organisms (GMOs) Biosafety. Brazil has also approved a new biosafety law last year.

3. Does your country have any guidelines or regulations for minimizing the impacts of genetically modified trees for scientific and/or commercial purposes?

Yes. Brazil has regulations for minimizing the impacts of GMTs for scientific and commercial purposes, taking into account environmental, health, cultural and socio-economic aspects. There is a specific Biosafety Technical Committee in Brazil that regulates genetically modified organisms. The genetically modified tree projects are submitted for approval under this Committee. The projects are analyzed case-by-case by experts and they are also submitted to ad hoc consultations.

The Brazilian Government has approved, in 2005, the Biosafety law that gives to CTNBio the responsibility to create technical rules that must be followed by the companies and institutions which have activities with GMOs. The first Biosafety Law in Brazil was edited in 1995 and established the case by case analyses of all Genetically Modified Organisms before its use. The main goal of this law is to guarantee the protection of the environment and human health when GMOs experiments are designed.
All Brazilian Institutions or companies that work with GMOs must obtain the "Biosafety Quality Certification" - CQB issued by CTNBio. This certification assures that all GMOs experimental activities carried out by the companies and institutions strongly follow biosafety rules.

Brazil has developed biosafety regulations that are consistent with the risk assessment recommendations in Annex III of the BSP, based on the biology of the species and a case-by-case approach that is flexible enough to be able to address the diverse biology found among all plant species, including trees.

This case-by-case approach is important in order to deal with the diverse biology of tree species: fruit or forestry species; short or long lived, self fertile or self incompatible, insect or wind pollinated, adaptation to specific environments, native or exotic, that would be impractical to address if separate specific guidelines were considered for all trees.
The actual experience with GM plants that has been accumulated shows a perfect safety record. Although activist groups proclaim many negative impacts there is no credible scientific evidence that there have been any harm to humans or to biodiversity. The scientific consensus on appropriate procedures for risk assessment has lead to specific science based regulations that have been put into place in Brazil as well as in countries like Canada, the United States, Argentina, the Philippines, South Africa, and others, based on the indicators of OECD, FAO, UNEP, the US National Academy of Sciences, the UK Royal Society, the Third World Academy of Science, between others.
Environmental impacts of genetically modified trees

Potential environmental impacts are addressed as a key consideration within Brazil’s regulations for all plant species, including GM trees. The biology of the target species is evaluated as well as the impacts of the genes introduced, be they for herbicide tolerance or any other trait. By careful review of the information submitted for a request for a confined field trial, the system allows for the safe testing of genetically modified organisms without undue risk to native ecosystems. Any potential negative impacts must be considered and addressed in order to receive approval for any introduction into the environment.

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  Any regulatory system should also allow for the assessment of positive environmental impacts. Technological advances have the potential to reduce pressures on native ecosystems by increasing productivity within existing production areas in order to meet increasing consumer demands. In addition, reductions in energy consumption and the environmental footprint of production technologies are possible by improving characteristics to allow more efficient processing and reduction in waste streams. Other potential applications include developing efficient feedstocks for biofuels as alternatives to dependency on fossil fuels, together with associated broad global benefits.
  

Brazil is developing several projects with genetically modified trees, with Eucalyptus, Papaya and Citrus. Usually the genetically modified trees are exotic species, like eucalyptus, and they cannot cross with any of the native species.

Cultural impacts of genetically modified trees

(Example: positive or negative impacts on indigenous and local communities and their traditional knowledge)

Positive cultural impacts can be accomplished from reduced pressure on native forest ecosystems. Faster growth or higher fiber yields from plantation forests can help to meet consumer demands. Developing more efficient and more cost effective fiber supply through existing managed plantations could help to significantly reduce logging in native forests and the associated negative environmental and cultural impacts of deforestation.

There are no evidences of negative cultural impacts with the adoption of genetically modified trees in Brazil. Eucalyptus and Citrus, are industrial purpose species normally. Different from other planted vegetal species, the commercial forest plantations are predominantly made by companies that are regulated periodically by independent quality control programs and by the state itself, and this results in plantation forests strictly planted according to Brazilian environmental laws. The small producers purchase their plants from professional plants producers or they are supported by the forestry companies. They do not use to make their own plantlets in the farm.

(Example: positive or negative effects on quantity, quality and economic value of forest production; positive or negative impacts on livelihoods of communities).
Economical impacts of genetically modified trees

In other countries the livelihoods of papaya farmers were saved through the introduction of genetically modified virus resistant papaya. Without the genetic modification approach this disease is untreatable and can devastate papaya growing communities. Local communities whose livelihoods depend on a crop that is threatened by disease should be given an opportunity to look to new technologies, including genetic engineering, to combat such threats. It is important that Brazil also has the opportunity to research and develop these kinds of solutions, not just in papaya, but for other tree species that could be threatened by diseases where genetic modification could be the best strategy. Impeding the development and deployment of such new technologies leaves countries and communities at a disadvantage in the global economy.

We ask the Secretariat to account fully for the potential positive effects from genetically modified trees, based on a case by case Biosafety evaluation. Rather than creating barriers to technology based solutions to problems, we should encourage the safe development of new technologies. In addition to protection from diseases, new technologies could allow the development of sustainable energy sources at the local level through higher yields and stress resistance trees. The failure to develop such technologies could have significant negative socioeconomic impacts.