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Update from the GM-Free Brazil Campaign
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Dear friends,


Translation from Portuguese of Dr. Lia Giraldo's letter of resignation from CTNBio

Brasilia, 17 of May of 2007.

Dear Honorable Minister of Science and Technology
Dear Honorable Minister of the Environment
Most Illustrious President of the Brazilian National Technical Biosafety Commission - CTNBio

Referring: Letter of resignation from the Brazilian National Technical Biosafety Commission and declaration of reasons.

It's been 31 years I am a dedicated public servant in the field of Collective Health, of which 20 years as a Hygienist doctor, having worked in the siderurgical-petrochemical region of Cubatão - São Paulo State, promoting both the workers' and general environmental health. I did both my master's and doctor degrees investigating biomarkers for risk analysis. It's been ten years I am senior researcher of the Oswaldo Cruz Foundation and professor of the Post-Graduate program of the Aggeu Magalhães Research Center, where I am responsible for the essential subjects of "Philosophy of Science and Bioethics" and "Advanced Research Seminars".

As technician, manager, scientist and teacher I had that to deal with various situations of conflicts of interests which frequently emerged in acute form, being clear to me that conflicts are part of the social process and therefore must be subordinated to the rules of civilized coexistence, respecting law, civil rights and democracy.

I am regular member of CTNBio as "Environment Specialist", legally appointed by the Brazilian Forum of Non-Governmental Organizations, from a triple list submitted to the Minister of the Environment. Today, after fifteen months of my nomination, I ask for my formal resignation from this Commission and present as a theme for reflection some critical opinions to help the improvement of the field of biosafety in our country.

In my opinion, Brazilian Federal Law 11.105/2005 that created CTNBio made a great mistake in removing from the national regulating and inspecting agencies the powers of analysis and decision on the processes relating to transgenics organisms, especially the commercial releases.

CTNBio is formed by people with doctor degrees, who are in their majority biotechnology specialists directly interested in the development of genetic engineering. There are only a few specialists in biosafety, actually capable of evaluating health and the environmental risks.

The members of CTNBio have a temporary mandate and they are not directly linked to the public sector with specific functions. So they are not legally liable for resulting problems of either the approval or the denial of GMOs release processes in the long run.

CTNBio is neither a promotion agency for research or postgraduate studies, nor a peer-reviewing council for an academic or scientific journal. The behavior of the majority of its members is one of belief in a science of monocausality. However, we are dealing with complex questions, with many uncertainties and with consequences over which we do not have control, especially when dealing with GMO releases in the environment.

Not even the Principle of the Uncertainty, that granted to the Nobel Prize to Werner Heisenberg, is considered by the majority of the so-called scientists that compose CTNBio.

Thus, also in the practice of the majority of CTNBio's members, the Precautionary Principle - one of the most important pillars of the Cartagena Protocol on Biosafety, which must guide both political e administrative actions of the signatory governments, is disregarded.

What we see in the daily practice of CTNBio are preconceived votes and a series of obscurantist cunnings aimed to consider the biosafety questions as difficulties to the advance of the biotechnology.
The reason at stake in the CTNBio game is the rationality of the market, that it is protected by a scientific rationality of the cartesian certainty, where the spalling or fragmentation of a knowledge dominated by several technicians with doctor's degrees, hinders the biosafety priorities and the perspective of technology in favour of better quality of life, health and environment.

There are no arguments which mobilize this crystallized rationality as the only "scientific truth", besides the inelegant form in the treatment of whosoever exert their (CTNBio) advocacy in the strict public interest.

To participate in this Commission required a great effort of tolerance facing the bizarre situations I lived in there - as the rejection of the majority of members in signing the "conflict of interests terms"; of the majority of members feeling constrained with the presence of a member of the Public Prosecution Service or credential representatives of the civil society in the meetings; of them being unwilling to accept the request for a public audience to debate the commercial release of transgenic maize, having the social movement to make use of a judicial resource to guarantee it's basic right; besides other vices in the votings of processes of commercial interest.

The lack of structure of CTNBio's General Secretariat is yet another question that makes us think how is it possible to have transferred so much responsibility to this Commission, without the necessary means to exert it. I saw innumerable problems related with the instruction and the transaction of processes occur, due to the lack of both material and human resources at CTNBio.

To illustrate this, I can quote process no. 01200.000782/2006-97, of AVIPE's (a poultry producers' association), which requested the revision of a decision of the CNBS (the Brazilian National Biosafety Council of Ministers of State). The process was given by the General Secretariat to a single CTNBio member for analysis, as a simple GM maize import process to feed chickens. Thanks to the interpretation of another member that it would be necessary to nominate more than one specialist for a valid opinion - regarding the old problems of this process with the ANVISA regulating health agency and the Ministry of the Environment (MMA) who had interposed arguments to the CNBS, it was possible to discover that the process was mistaken. Even more because CTNBio alone could only judge seed import requests for scientific experiments. Commercial grain imports for animal rations, for example, are not attributions of CTNBio.

Another illustrating fact is the case of the commercial release of the vaccine against Aujeski's disease of swine (in which I was one of the reporters). The only four votes against the release would not be enough for its rejection. However, the fact of not having 18 favourable votes hindered its approval and was used widely to justify the reduction of the CTNBio quorum from 2/3 to simple majority in the votings of GMOs commercial releases. It occurred that my report contrary to the approval of this process brought into discussion a series of arguments that have not even been considered by those members who were already determined to vote for its release.

This vaccine is in the international market for fifteen years and is commercialized only in five countries, none of them part of the European Community. This detail took me to investigate its reasons and I've found a series of questions and precautions against its use in swine health, regarding the risks of contracting Aujeski's disease, that are also followed by Brazilian authorities.

Unfortunately this fact was politically used in the National Congress as an argument to justify the reduction of the CTNBio quorum for commercial releases (from 18 to 14 votes), showing that the commercial interests surmount the ones of biosafety with the consent of CTNBio's.

In such a way, with the due respect to citizenship and my professional trajectory as a scientist and former of human resources, I will not be able anymore to remain as member of a National Technical Biosafety Commission that, in my opinion, does not have the conditions to respond to the attributions that the law confers to it.

I wish that a deep reflection inspire all those who have public responsibility so that the agencies with technical competence and exemption of interests can in fact assume the role that the State must have in the protection of health, the environment, society, democracy and sustainable development.

Brasilia, 17 of May 2007.
Prof. Dr. Lia Giraldo da Silva Augusto
Regular member of the CTNBio
Environment Specialist
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