Petition To The European Parliament: EFSA Violates EU Consumers' Rights
Name: Brian John
Postal Address: provided
Nationality: Welsh
Hosting MEP: Kathy Sinnott, MEP Ireland South
Title of Petition: The importance of impartiality within EFSA & the food safety rights of EU citizens
Text of Petition (No. 0813/2008):
The European Food and Safety Agency (EFSA) was designed to improve food safety in the EU, to restore the faith of EU citizens in EU food and guarantee consumer protection. As such, EFSA claims to provide "independent scientific advice [which] underpins the European food safety system"[1]. As citizens who should be served by this remit of EFSA we petition the European Parliament today because we see that the modus operandi of EFSA means it cannot be neutral or independent and thus violates the rights of all EU consumers to clean, safe and healthy food.
It is our assertion that EFSA does not operate according to EU law, namely Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety. In addition principles of European Consumer Law are being disregarded, and priorities laid down in the Sixth Framework Programme (2000-2006): food quality and safety (2002/835/EC).
As an independent risk assessor, EFSA should not base its assessments of GM foods and crops on "advocacy science" submitted by applicants, which is by definition partial, selective and biased. Yet it continues to do so, despite the fact that some such science may also be fraudulent, since the application dossiers from GM corporations and patent owners cannot be examined in full by members of the public and by independent scientists and thus cannot be subjected to a proper process of peer review. Thus when dossiers are assembled, companies can simply omit "inconvenient" findings; they can also "manufacture" favourable results by the aggregation of data with a view to masking effects, by the use of insensitive testing techniques, by statistical manipulation, and by careful experimental design. Such practices are fraudulent, and they place Europeans at risk since GM crops and foods cleared as "safe" on the basis of dossier evidence may in fact be dangerous.
Furthermore, and more importantly, the science which is assessed by EFSA is for the most part non-replicable science which should never be admitted as valid, let alone considered in detail and acted upon. It is a fundamental principle of science that all experiments must be replicable if scientific fraud is to be avoided -- and yet EFSA never asks for replicability. (It has occasionally asked for supplementary evidence, but never for full independent replication of experiments.) Those who apply for approvals for GM crops and foods systematically block research by refusing to supply GM seeds, reference materials and chow for animal feeding experiments by independent scientists or institutions; this means that the dossier experiments cannot be replicated or improved, and that results cannot be verified or questioned. In Hungary, for example, Monsanto refused to supply MON810 seed to Professor Darvas and colleagues as soon as their research started to throw up negative environmental effects. Another example is in France, where Monsanto refused to supply MON863 materials for experiments designed to replicate or test the results reported in the MON863 dossier. Both examples clearly violate the terms under which EFSA operates namely Article 38 (concerning Transparency) of Regulation 178/2002 Section 4.
These concerns lead us to ask that the Parliament instruct EFSA to enforce the highest standards of scientific ethics in its own GMO Panel and in the dossiers of GM applicants, thereby safeguarding the health of citizens as per its original remit. We ask that EFSA be instructed to insist on full and early release of all scientific data contained in dossiers, and to insist on signed declarations from applicants relating to replicability, so as to enable a full and independent verification (or falsification) of apparent findings.
As EU citizens with rights we are being discriminated against by EFSA who, rather than protecting us, are supporting the commercial ambitions of the GM companies and "enabling" their approvals. We wish to emphasize the fact that there are no benefits to consumers in terms of taste, quality, shelf-life, price, and nutritional value of GM crops and foods -- the only benefits are to farmers wishing to reduce labour costs and spend less by using chemicals, and to the companies that own the seed and sell the herbicides / pesticides. It is valid for certain EU institutions, such as those involved in trade and agriculture, to support these corporate ambitions but EFSA should represent citizens and not business interests. EFSA exists to provide a service to EU citizens and the European institutions, and it must therefore treat consumers as its number one priority. It is our view that the current modus operandi of EFSA fails to do this, implying that EFSA has breached its responsibility to European consumers and to Regulation 178/2002 Section 4: Article 37-40 on Independence, Transparency, Confidentiality and Communication.
Kathy Sinnott MEP is the hosting MEP for this petition.
[1] http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_home.htm
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COMMENT FROM GM-FREE CYMRU
With respect to this section:
As an independent risk assessor, EFSA should not base its assessments of GM foods and crops on "advocacy science" submitted by applicants, which is by definition partial, selective and biased. Yet it continues to do so, despite the fact that some such science may also be fraudulent, since the application dossiers from GM corporations and patent owners cannot be examined in full by members of the public and by independent scientists and thus cannot be subjected to a proper process of peer review. Thus when dossiers are assembled, companies can simply omit "inconvenient" findings; they can also "manufacture" favourable results by the aggregation of data with a view to masking effects, by the use of insensitive testing techniques, by statistical manipulation, and by careful experimental design. Such practices are fraudulent, and they place Europeans at risk since GM crops and foods cleared as "safe" on the basis of dossier evidence may in fact be dangerous.
our concerns are now shown to have been absolutely justified. Recent research papers in the peer-reviewed and government-sponsored literature show that maize NK603xMON810, maize MON810, and Monsanto Roundup-ready soy cause actual harm (directly attributable to the GM "events" concerned) to animals which consume these materials in feeding trials (1)-(5). These harmful effects have occurred in spite of the fact that EFSA has examined all of these GM varieties on more than one occasion, and has declared them to be safe in all respects. EFSA has also reaffirmed its confidence in the safety on MON863 and NK603, in spite of the recognition of statistically significant physiological changes in animals fed on those varieties, and in spite of the attempts by the owners of these varieties to "mask" these effects in their application dossiers (6)(7). This means that EFSA is incompetent or corrupt, and that it is not effectively protecting the European consumer.
We therefore call for the disbanding of EFSA's GMO Panel and the fundamental reform of EFSA itself. Since it is obvious that harmful materials have already passed through the EFSA assessment procedure, leading to unreliable and dangerous advice to the Commission, it follows that there must now be a freeze on all future GM approvals and a reassessment of all of the past science relating to approved GM varieties. It also follows that any “speeding up”, simplification” or “streamlining” of the EU’s GM assessment procedure would be directly against the public interest and could be deemed to be criminally negligent.
References:
(1) Velimirov A, Binter C and Zentek J. (2008) Biological effects of transgenic maize NK603xMON810 fed in long term reproduction studies in mice. Report, Forschungsberichte der Sektion IV, Band 3. Institut für Ernährung, and Forschungsinttitut für biologischen Landbau, Vienna, Austria, November 2008.
(2) Finamore A, Roselli M, Britti S, Monastra G, Ambra R, Turrini A and Mengheri E. (2008). Intestinal and peripheral immune response to MON810 maize ingestion in weaning and old mice. J Agric Food Chem, http://pubs.ac.org, 16 November 2008
(3) Kilic, A. and M. T. Akay (2008). A three generation study with genetically modified Bt corn in rats: Biochemical and histopathological investigation. Food Chem. Toxicol. 46(3): 1164-1170.
(4) Manuela Malatesta, Federica Boraldi, Giulia Annovi, Beatrice Baldelli, Serafina Battistelli, Marco Biggiogera, Daniela Quaglino. (2008) A long-term study on female mice fed on a genetically modified soybean: effects on liver ageing. Histochem Cell Biol. 2008 Jul 22; : 18648843 (P,S,G,E,B,D)
(5) M Malatesta, F Perdoni, G Santin, S Battistelli, S Muller, M Biggiogera (2008) Hepatoma tissue culture (HTC) cells as a model for investigating the effects of low concentrations of herbicide on cell structure and function. Toxicol In Vitro. 2008 Sep 18; : 18835430 (P,S,G,E,B,D)
(6) Séralini, G-E, Cellier, D. & Spiroux de Vendomois, J. 2007. New analysis of a rat feeding study with a genetically modified maize reveals signs of hepatorenal toxicity. Archives of Environmental Contamination and Toxicology DOI: 10.1007/s00244-006-0149-5.
(7) http://www.gmfreecymru.org/pivotal_papers/monsanto2