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COMMENTS ON GMO ACT AMENDMENT BILL

COMMENTS ON GMO ACT AMENDMENT BILL. Braam Olivier African Products (Pty) Ltd. INTRODUCTION (1).

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COMMENTS ON GMO ACT AMENDMENT BILL

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  1. COMMENTS ON GMO ACTAMENDMENT BILL Braam Olivier African Products (Pty) Ltd

  2. INTRODUCTION (1) African Products is a company that produces value added products from maize to meet the demands and requirements of our highly valued customers. Thus, with regard to GMO’s, African Products position on GMO’s is totally neutral, and wants to ensure than any legislation or regulations governing GMO’s will allow for its continued service to its customers, to meet their demands, nationally as well as internationally.

  3. INTRODUCTION (2) • POSITION STATEMENT • AMENDMENTS TO THE GMO ACT • THE REGULATIONS • OTHER COMMENTS

  4. POSITION STATEMENT (1) • African Products is not against permitting GMO’s in South Africa. • African Products is not against the GMO Act 15 of 1997 and welcomes the Amendment Bill. • It is a fallacy to believe that there is only people for and people against GMO’s

  5. POSITION STATEMENT (2) • Furthermore, African Products do believe that GMO’s could bring about huge advantages in future, for example: • Increase efficiencies in crop production • Increased production in staple food world wide • Food security and alleviation of hunger • Increased competitiveness and stability in remote areas

  6. POSITION STATEMENT (3) • However, African Products has to deal with the commercial issues brought about by GMO’s • Unfortunately, most of the commercial issues are dealt with in the Regulations, which are not looked at during this process of amendments to the Act.

  7. PROPOSED AMENDMENTS TO THE GMO ACT (1) • Most of our concerns are already built into the latest version of the amendments. • Definitions: Need clarity in regard to terminology used in Act vs Regulations and permits - import for planting - unconditional release - general release - conditional general release - no definition for facility - international responsibility of transboundary movement

  8. PROPOSED AMENDMENTSTO THE GMO ACT (2) • Section 5: (2) The comment “may”? – decisions from Council is suggested but not certain • Section 9: (1)(d) satisfy himself or herself [Registrar] (3) issuing of extension permits could be abused • Section 10: Advisory Committee “-composition” 8 knowledgeable people in these fields of science applicable to the development and release of GMO 2 Public sector – ecological matters/human and animal health

  9. PROPOSED AMENDMENTSTO THE GMO ACT (3) • Section 15: Inspectors The Act weak in “duties” of inspectors especially in regard for instance to “conditional general release” of “commodity clearance” • Section 17: Still concern over the term “user” in regard to risk and liability – there should be a clear cause analysis to establish liability to protect farmers, procedures and consumers • Section 19: (4)(c) “significant” • Section 20: The Minister may make regulations – thus no certainty

  10. THE REGULATIONS • Last update on website seems to be 26/11/1999 • Terminology not consistent - import for planting - commercial planting - unconditional general release • Commodity clearance - who’s responsibility - how/where check/analysis/methods - how to secure “stay out from mainstream”

  11. OTHER COMMENTS • The fallacy of improved yields from Bt and RUR maize, together with responsibilities from seed suppliers • Exports: Credibility of SA as supplier of non-GMO products and commodities – still no action on GMO labelling • Issue of permits versus ability to analyse – commercial and cost implications • Bt11 – Case study for GMO Act and Regulations Cry1Ab + PAT / a “GA” type weed killer not registered for maize • Use of SA as transit country (US maize to Zimbabwe)

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