PHM-Exch> URGENT GM Mosquitoes international Sign-on
Evelyne Hong
ehong at twnetwork.org
Mon Dec 20 00:06:45 PST 2010
apologies for cross-postings*
*not for public circulation yet, embargoed till 20 Dec 2010*
Dear friends and colleagues
GM mosquitoes are poised for release in Malaysia and have already been released in the Cayman Islands. There are many serious concerns about these GM mosquitoes. As such, we have drafted the following statement of concern (attached and pasted below) from civil society organizations, for which we are seeking international organizational endorsements. Please also circulate widely to your networks so we can get as many signatures as possible, but note that the letter should not be made public yet. The letter will be sent to the relevant ministries and agencies in Malaysia on 20 December. We apologize for the short turn around time, but the matter is urgent as we fear that field releases may have already occurred.
Please send all organizational endorsements to twnkl at twnetwork.org by 5pm (GMT), 20 December, Monday.
Many thanks,
Lim Li Ching and Lim Li Lin
Third World Network (TWN)
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To:
Y.B. Dato' Sri Liow Tiong Lai, Minister of Health
Y.B. Dato Sri Douglas Uggah Embas, Minister of Natural Resources and Environment
Tan Sri Dato' Sri Dr Hj Mohd. Ismail bin Merican, Director General of Health
Dato' Zoal Azha bin Yusof, Secretary General, Ministry of Natural Resources & Environment and Chairperson, National Biosafety Board (NBB)
Dr Shahnaz Murad, Director, Institute of Medical Research (IMR)
Mr Letchumanan Ramatha, Director General of Biosafety
Dr Ahmad Parveez Hj. Ghulam Kadir, Chairperson, Genetic Modification Advisory Committee (GMAC)
20 December 2010
Statement of concern from civil society organizations regarding field release of genetically modified mosquitoes
As civil society organizations from around the world, we write to you to respectfully put forward our views on the issue of the release of genetically modified (GM) Aedes aegypti mosquitoes in Malaysia. It is not clear if such releases have already occurred, but given the tremendous international interest in the issue, it would be regrettable if the field trials were to be shrouded in secrecy.
We are equally concerned by news of the field releases in 2009 and 2010 of the same GM mosquitoes in the Cayman Islands and call for a transparent assessment of the health and environmental impacts of these trials, pending which, no further field releases of GM mosquitoes should occur. The Cayman trials have also been strongly criticized for being conducted without public consultation or ethical oversight and for not seeking the informed consent from local people.
While we appreciate that dengue is a serious problem in Malaysia and that urgent measures are needed to address this debilitating disease, the release of GM mosquitoes presents a unique moment in the history of the application of genetic engineering technology, which is of international importance. We know that the government of Malaysia has not taken this decision lightly, and appreciate the efforts that have been made to responsibly assess the technology and the risks associated with the release of these GM mosquitoes into the environment.
Scientific uncertainties call for a precautionary approach
However, there are several outstanding scientific issues that would benefit from a more cautious approach. GM mosquitoes are a very new application of GM technology and present very different risks, and for which the international community has had virtually no risk assessment or regulatory experience.
Unintended and unpredictable changes may occur (often not instantly noticeable), and a focus on testing for these effects in the laboratory should be the first step, rather than testing fitness parameters in the open environment, as appears to be the intention of these field trials. Further, the interactions in the wild between the two dengue-carrying mosquito species, their predators and prey, the evolution of the diseases that they carry, and the human population should be better understood before introducing changes of this kind. This requires more sophisticated computer modelling, informed by a better understanding of the behaviour of unmodified mosquitoes in the wild.
It would be therefore prudent to ensure that any questions remaining should be first investigated in order to plug the data gaps that currently exist. As such, a precautionary approach dictates that it is still too early for any open field releases, especially given the fact that there will be GM mosquitoes, including females which potentially transmit disease, surviving in the environment due to the known leakiness of the technology employed. Of particular concern is whether the survival rates in subsequent generations will eventually select for mosquitoes that can overcome the conditional lethality trait. Survival of the GM larvae also means that the transgenes may not be completely removed from the environment, with unknown consequences.
Pitfalls of a GM mosquito strategy for dengue control
If the world is to approach dengue control using GM mosquitoes, we may be locking ourselves onto a 'genetic treadmill', which would be difficult to reverse. At the commercial release stage, the continuous release of millions of GM mosquitoes at several places would be needed in order to successfully suppress target mosquito populations. In such large numbers the concerns raised over the field trials would be magnified many times over, plus would raise other additional risks.
>From the public health perspective, of particular concern is whether population suppression of Aedes aegypti (which is the ultimate aim of these GM mosquitoes) would lead to other closely related and disease-transmitting species, such as Aedes albopictus, filling the vacated niche and hence continue to cause, or even worsen, the dengue problem, or transmission of other serious diseases.
The company that produces and owns the GM Aedes aegypti mosquitoes, UK-based Oxitec Limited, is also developing a similar GM Aedes albopictus mosquito, presumably in anticipation of this problem. Oxitec clearly stands to gain from the approval of its products in countries such as Malaysia. However, it is unclear who will bear the liability and from whom victims should seek redress, should any damage to the environment or human health or animal health occur.
Right to health and participation are priorities
Instead of a dengue control strategy beholden to private and vested interests, the participation of people and peoples' organizations is essential to and would benefit the formulation, implementation and evaluation of all health policies and programmes. We urge the Malaysian government to ensure meaningful and effective public participation on this matter, as it is committed to under its Biosafety Act 2007 and as a Party to the Cartagena Protocol on Biosafety. There is also a need to put in place a serious and proper prior informed consent regime, especially considering that the whole world will be looking to the Malaysian experience as a model.
Human well-being is at the core of public health and governments have a duty to respect, protect and fulfil peoples' right to health, as well as refrain from taking actions that can jeopardize the right to health of its citizens. We therefore respectfully urge the Malaysian government to reconsider the decision to allow field experiments of the GM mosquitoes, not only for the benefit of Malaysians, but also for the world at large.
Thank you for your kind consideration of our views.
Yours sincerely,
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