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24 January 2000

Delegates to the Extraordinary Meeting of the Conference of Parties
Convention on Biological Diversity
UN Environment Programme 393 Saint-Jacques Street, Suite 300
Montreal, Quebec H2Y IN9
CANADA

Dear Sir or Madam:

As the Extraordinary Meeting of the Conference of Parties (ExCOP 1) resumes today to negotiate the terms of a Biosafety Protocol, we Non-Governmental Organization representatives urge delegates to consider the very real threat that a Protocol not grounded in sound scientific principles could pose to the environment and to the well-being of human populations around the world.

Perhaps the most substantial threat comes from inclusion in the draft Protocol of the "precautionary approach" to the environmental and human health regulations: to wit, "Lack of a full scientific certainty or scientific consensus regarding the potential adverse effects of a living modified organism shall not prevent the Party of import from prohibiting the import of the living organism in question…" (UNEP/CDB/ExCop/1/L.2/Rev. 1, pg. 32). Such a precautionary approach - which demands that new technologies be proved absolutely safe before they can be used - necessarily ignores the very real dangers of going without the technologies. A more progressive approach would balance the risk of introducing new biotechnologies against the much more pressing risks of hunger and poverty.

Living Modified Organisms - that is, those developed with recombinant DNA techniques and other advanced biotechnologies - offer one of the best hopes for increasing the productivity and affordability of crop plants and for making medicines more affordable and easier to distribute. In many areas, this potential has already been demonstrated. And, contrary to the claim of anti-biotechnology activities, LMOs can even advance environmental goals because they require less pesticide and herbicide use and because they allow more food to be grown with less land. Adherence to a precautionary approach is unlikely to make new food technologies safer. It could, however, create its own risks by postponing the time when the benefits of LMOs reach farmers and consumers.

There is no scientific reason to believe that the use of recombinant DNA techniques or other advanced bio-technologies inherently poses new or more dangerous threats to biodiversity, to other aspects of environmental quality or to human health, than do traditional methods of plant breeding or cell culture. By using science-based risk assessment and risk management guidelines enshrined in such other international agreements as the Sanitary and Phytosanitary standards agreement, the Technical Barriers to Trade agreement, and the International Plan Protection Convention, nations and regulatory bodies can effectively manage the legitimate risks posed by both LMOs and organisms modified with more traditional methods. If an unscientific Protocol is allowed to trump these other international obligations, governments will be permitted to base public policies not on science, but on baseless fears and emotionalism.

Attached below, you will find a declaration signed by more than 600 scientists from around the world in support of using agricultural biotechnology. We urge you to consider this declaration and the importance of new biotechnologies as the negotiations on the Biosafety Protocol commence.

Sincerely,

Professor C.S. Prakash
Director, Center for Plant Biotechnology Research, Tuskegee University
Founder, AgBioWorld web site

Frances B. Smith
Founder and Director, International Consumers for Civil Society

Gregory Conko
Director, Food Safety Policy, Competitive Enterprise Institute

Barbara Rippel
Senior Policy Analyst for Trade and the Environment, Consumer Alert