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FROM THE INDEPENDENT SCIENCE PANEL (1)

Dr. Sawsan Ali Magid Al-Sharifi
Minister of Agriculture
Government of Iraq

13th March 2005

Dear Dr Sawsan

First, we wish to express our good wishes to you and your colleagues in the new Administration in Iraq, and to wish you a time of peace and security as you rebuild your country after a long history of difficult and indeed tragic events.

We appreciate that following your Election and the establishment of a popular Government, you have many urgent priorities to deal with across the board, not least within your Agriculture portfolio.  However, we respectfully urge you to address one particular issue which is liable to cause great harm to your farming community, to your environment, and indeed to the national integrity of your country.  This issue is causing great concern throughout the world, particularly among groups which have interests in farmers' rights, biosafety and biosecurity.

We refer to Order 81 which was put in place by Administrator Paul Bremer for the CPA on 26th April 2004. This Order, which we understand to have been written almost entirely by the American "advisers" to the CPA,  will (in the eyes of many aid organization) do grave damage to the social, economic and political wellbeing of Iraq; and others may well make representations with these matters in mind. So that you may gauge the strength of feeling across the world, please enter "Iraq" + "Order 81" into a Google search; you will find that there are 7,530 entries.

As concerned scientists with a breadth of expertise in agricultural risk assessment, we wish to make a number of points relating to the scientific impacts of the Order, and to highlight the damage which it will do to Iraqs agricultural future.

1. GENETICALLY MODIFIED (GM) CROPS.

The Order promotes the view that GM varieties are really no different from "new" varieties developed through conventional breeding programmes.  This view is scientificallty indefensible, and the many unique health and environmental hazards associated with GM crops and foods are now well documented in the scientific literature, particularly within Europe (2).  For this reason the EU has put in place a series of measures designed to safeguard the environment and the wellbeing of the public from  contamination by genetically modified organisms (GMOs).

2.  PATENTING.

Although the Order is supposed to deal with plant variety protection (PVP) it goes a great deal further than that, and it paves the way for the patenting of life forms in line with the thinking of the American Administration.  You will be aware that this raises profound ethical concerns, and that there are many governments and religious groups throughout the world who are implacably opposed to the "patenting" of crop varieties which can be promoted as "new" but which are based upon centuries of careful breeding and adaptation by generations of farmers.  Iraq and the Fertile Crescent of course have a special place in the history of agriculture as the "nurseries" of many cereal varieties, and in our view it would be a tragedy if the genetic diversity of your seedbanks was to be controlled or compromised by private entities including the transnational biotechnology corporations.  These corporations will portray this as "progress", but it will be nothing of the sort.

3. BIODIVERSITY.

This is not specifically addressed in Order 81, but the implementation of the Order will have at least two negative effects.  The number of cultivated crop varieties will be reduced as "common knowledge" varieties are squeezed out and as "high-quality" or new registered varieties are brought in by the large seed merchants.  Those merchants have a long history of buying up small seed suppliers and their catalogues, and systematically reducing the number of varieties on sale.  This, in our judgement, is what will happen in Iraq also.  Secondly, biodiversity will be negatively affected by the use of agrichemicals and by GM contamination through out-crossing from, for example, GM wheat to wild relatives.  It is now well known that such out-crossing is completely predictable, and that the co-existence of GM crops and non-GM crops and related landraces is impossible.  This is of particular concern for centres of crop origin and diversity, such as Iraq and Mexico.

4.  SEED SAVING. 

This is to do with farm management rather than science, but we feel very strongly about it since it is related closely to the points made above.  The saving and re-use of seeds is a key practice in the maintenance of biodiversity and also demonstrates to the world the intellectual property rights of farming families who have bred and improved "common knowledge" varieties over many generations.  We consider that the patrimony of your country is at stake here, and that your attitude to Order 81 will affect the lives of Iraqi people for generations to come.  The Order does not in itself prohibit the practice of seed saving, but in the present context of shortages of capital and farm labour, ARDI assistance, and agricultural reconstruction programmes, we are concerned that -- in the absence of clear Government guidance --  thousands of farmers may simply be sucked into a high-input cash-crop economy based upon the use of registered seed varieties and associated agrichemicals.

Finally, we should like to point out that the preamble to Order 81 is cynical and opportunistic.  Its provisions are justified as "necessary to improve the economic condition of the people of Iraq", as desirable for "sustainable economic growth" and as enabling Iraq to become "a full member of the international trading system known as the WTO."   We do not accept any of these justifications.   In our view the adoption of Order 81 will do great damage to the economic fortunes of the Iraqi people, will damage sustainable economic growth, and inhibit full participation in international trade.  To mention but one negative effect, if GM crops are grown within your country you will find it impossible to control GM contamination levels and will almost certainly lose large potential markets within the EU and in many other countries.

We urge you to revoke Order 81, and to replace it with other laws which are more sensitive to the needs of Iraqi farmers, to environmental concerns, and to health and safety issues.  We invite you to look at  the following paper which addresses some of the social, economic and political concerns of those who have examined the wording of Order 81: http://www.i-sis.org.uk/GMiraq.php In the report entitled "The Case for a GM-Free Sustainable World" (136pp) we summarize the unique dangers associated with GM crops and foods.  Please take time to examine this summary:


https://www.indsp.org/ISPreportSummary.php

Thank you very much for your consideration.   If you wish to raise any points relating to the contents of this letter, please do not hesitate to come back to us.  We are sure that we will be able to help you with specific scientific advice. We look forward to hearing from you.

Yours sincerely.


Dr Brian John,

On behalf of the members of the Independent Science Panel



References

(1)  ISP is a panel of scientists from many disciplines, committed to the promotion of science for the public good.  For a statement of key objectives, please see the following:
https://www.indsp.org/statement.php
For a list of members and biographies, please see the following:
https://www.indsp.org/ISPMembers.php

(2)  See, for example, Freese, W & Schubert, D. 2004. "Safety Testing and Regulation of Genetically Engineered Foods",  Biotechnology and Genetic Engineering Reviews, 21: 299-324; Blandford, S. "Argentina's Bitter Harvest", New Scientist, 17th April, 2004; Open Letter from World Scientists to All Governments Concerning Genetically Modified Organisms (GMOs) (745 signatures to date) http://www.i-sis.org.uk/list.php

 
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