Civil society groups in Malaysia have written to the authorities, urging them not to go ahead with their proposed – and already deferred – release of genetically modified mosquitoes.
Mr Letchumanan Ramatha, Director General of Biosafety
Dr Ahmad Parveez Hj. Ghulam Kadir, Chairperson, Genetic Modification Advisory Committee (GMAC)
20 December 2010
Re: Statement of concern from international civil society organisations regarding field release of genetically modified mosquitoes
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As international civil society organizations working primarily in the fields of public health, biosafety, and consumer and environmental protection, we write to you to respectfully put forward our views on the issue of the release of genetically modified (GM) Aedes aegypti mosquitoes in Malaysia. It is not clear if such releases have already occurred, but given the tremendous international interest in the issue, it would be regrettable if the field trials were to be shrouded in secrecy.
We are equally concerned by news of the field releases in 2009 and 2010 of the same GM mosquitoes in the Cayman Islands and call for a transparent assessment of the health and environmental impacts of these trials, pending which, no further field releases of GM mosquitoes should occur. The Cayman trials have also been strongly criticised for being conducted without public consultation or ethical oversight and for not seeking the informed consent from local people.
While we appreciate that dengue is a serious problem in Malaysia and that urgent measures are needed to address this debilitating disease, the release of GM mosquitoes presents a unique moment in the history of the application of genetic engineering technology, which is of international importance. We know that the government of Malaysia has not taken this decision lightly, and appreciate the efforts that have been made to responsibly assess the technology and the risks associated with the release of these GM mosquitoes into the environment.
Scientific uncertainties call for a precautionary approach
However, there are several outstanding scientific issues that would benefit from a more cautious approach. GM mosquitoes are a very new application of GM technology and present very different risks, and for which the international community has had virtually no risk assessment or regulatory experience.
Unintended and unpredictable changes may occur (often not instantly noticeable), and a focus on testing for these effects in the laboratory should be the first step, rather than testing fitness parameters in the open environment, as appears to be the intention of these field trials. Further, the interactions in the wild between the two dengue-carrying mosquito species, their predators and prey, the evolution of the diseases that they carry, and the human population should be better understood before introducing changes of this kind. This requires more sophisticated computer modelling, informed by a better understanding of the behaviour of unmodified mosquitoes in the wild.
It would be therefore prudent to ensure that any questions remaining should be first investigated in order to plug the data gaps that currently exist. As such, a precautionary approach dictates that it is still too early for any open field releases, especially given the fact that there will be GM mosquitoes, including females which potentially transmit disease, surviving in the environment due to the known leakiness of the technology employed. Of particular concern is whether the survival rates in subsequent generations will eventually select for mosquitoes that can overcome the conditional lethality trait. Survival of the GM larvae also means that the transgenes may not be completely removed from the environment, with unknown consequences.
Pitfalls of a GM mosquito strategy for dengue control
If the world is to approach dengue control using GM mosquitoes, we may be locking ourselves onto a ‘genetic treadmill’, which would be difficult to reverse. At the commercial release stage, the continuous release of millions of GM mosquitoes at several places would be needed in order to successfully suppress target mosquito populations. In such large numbers the concerns raised over the field trials would be magnified many times over, plus would raise other additional risks.
From the public health perspective, of particular concern is whether population suppression of Aedes aegypti (which is the ultimate aim of these GM mosquitoes) would lead to other closely related and disease-transmitting species, such as Aedes albopictus, filling the vacated niche and hence continue to cause, or even worsen, the dengue problem, or transmission of other serious diseases.
The company that produces and owns the GM Aedes aegypti mosquitoes, UK-based Oxitec Limited, is also developing a similar GM Aedes albopictus mosquito, presumably in anticipation of this problem. Oxitec clearly stands to gain from the approval of its products in countries such as Malaysia. However, it is unclear who will bear the liability and from whom victims should seek redress should any damage to the environment or human health or animal health occur.
Right to health and participation are priorities
Instead of a dengue control strategy beholden to private and vested interests, the participation of people and peoples’ organisations is essential to and would benefit the formulation, implementation and evaluation of all health policies and programmes. We urge the Malaysian government to ensure meaningful and effective public participation on this matter, as it is committed to under its Biosafety Act 2007 and as a Party to the Cartagena Protocol on Biosafety. There is also a need for a more vibrant prior informed consent regime, especially considering that the whole world will be looking to this Malaysian experience as a model.
Human well-being is at the core of public health and governments have a duty to respect, protect and fulfil peoples’ right to health, as well as refrain from taking actions that can jeopardise the right to health of its citizens. We therefore respectfully urge the Malaysian government to reconsider the decision to allow field experiments of the GM mosquitoes, not only for the benefit of Malaysians, but also for the world at large.
Thank you for your kind consideration of our views.
Yours sincerely,
PAN AP
See the open letter from civil society groups:
17 December 2010
To:
Y.B. Dato’ Sri Liow Tiong Lai, Minister of Health
Y.B. Dato Sri Douglas Uggah Embas, Minister of Natural Resources & Environment
Tan Sri Dato’ Sri Dr Hj Mohd. Ismail bin Merican, Director General of Health
Dato’ Zoal Azha bin Yusof, Secretary General, Ministry of Natural Resources & Environment and Chairperson, National Biosafety Board (NBB)
Mr Letchumanan Ramatha, Director General of Biosafety
Dr Shahnaz Murad, Director, Institute of Medical Research (IMR)
Dr Ahmad Parveez Hj. Ghulam Kadir, Chairperson, Genetic Modification Advisory Committee (GMAC)
Re: Open letter from Malaysian NGOs on genetically engineered Aedes aegypti mosquitoes
We, the undersigned organizations of Malaysia, representing the public health, environmental, consumer and other movements, are very concerned by the recent approval to release genetically modified (GM) male Aedes aegypti mosquitoes OX513A(My1), for the purpose of a field experiment. We are even more worried that the field releases may have already happened, without adequate notification or information provision to the public. We urge the government to be transparent on the issue and to immediately disclose the details and specific sites of the releases.
1. Risky approach to dengue control
While dengue is a very serious problem in Malaysia and needs to be urgently addressed, going down the GM path takes us into risky territory. Genetic engineering often results in unintended effects. We do not know enough about the GM mosquitoes and how their interactions with non-GM mosquitoes in the wild, other species in the ecosystem, the dengue virus and human populations, will be affected.
There are several health and environmental risks associated with the field releases. For example, a small proportion of the GM larvae will survive – some of which would be female – despite claims that the technology is safe because the larvae will die. As female mosquitoes bite humans and transmit disease, has the risk of an increased disease burden been assessed? The surviving GM larvae would also lead to the persistence of the GM genes in the environment, with unknown consequences.
2. Field trials a first step to large-scale release
Although the field releases are characterized as small-scale and limited, we are extremely concerned that they are but one step in a technological approach to dengue control that is based on dependency and ‘locking-in’. At the commercial release stage, the continuous release of millions of GM mosquitoes at several places in Malaysia would be needed in order to successfully suppress mosquito populations. The risks would be greatly amplified at such large numbers.
One serious concern is the likely possibility that other closely related and disease-transmitting species would take over the ecological niche of Aedes aegypti once its populations are successfully reduced. This would continue to cause, or even worsen, the dengue problem and may even cause a rise in other mosquito-borne diseases.
While we realize that large-scale and eventual commercial releases would have to undergo a separate approvals and risk assessment process, the government cannot afford to ignore the implications of going down the GM path and must consider these concerns, even at this early stage.
3. In the public or private interest?
We understand that Oxitec Limited, a UK-based company, holds the patents on the technology used in these GM mosquitoes. While Oxitec will presumably collect rewards for their invention, will they bear the liability should anything go wrong?
A review of Oxitec’s accounts (available from Companies House, which is the UK government agency responsible for registering limited companies) shows that it made losses in 2008 and 2009 of £1.7 million a year. While Oxitec has received grants for its research, it is clear that the company expects to gain income from continual releases of GM mosquitoes in large numbers in several countries.
4. Our demands
a. As citizens of Malaysia, we demand a wider and broader public debate on the issue than there has been to date. This field experiment will have tremendous implications for Malaysia’s health and environment. There must be a national discussion as to whether GM mosquitoes are indeed the right approach to address dengue. The general public are integral to effective dengue control and there must be consensus on this issue.
b. The prior informed consent of the communities living in and around the proposed field release sites must be obtained. This means that they must also have the potential risks of the study adequately explained to them, and information about the sources of funding and any possible conflicts of interest provided.
c. We ask the government to call off the experiment and field releases of the GM mosquitoes, and to instead invest in safer approaches to addressing dengue.
Thank you.
Yours sincerely,
1. Centre for Environment, Technology & Development, Malaysia (CETDEM)
2. Consumers’ Association of Penang (CAP)
3. Institute for Development of Alternative Living (IDEAL)
4. Malaysia Youth and Students Democratic Movement (DEMA)
5. Parti Sosialis Malaysia – Cameron Highlands Branch
6. Penang Suya Meiyarivagam
7. Persatuan Kakitangan Akademik Universiti Malaya (PKAUM)
8. Persatuan Karst Malaysia
9. Persatuan Kebajikan Nelayan-Nelayan Pantai Pulau Pinang (Penang Inshore Fishermens’ Welfare Association)
10. Persatuan Pengguna-Pengguna Pahang (PAC)
11. Persatuan Pengusaha Pertanian Kecil Felda Chini, Pekan, Pahang (Chini Smallholders Network)
12. Pesticide Action Network Asia and the Pacific (PAN-AP)
13. Sahabat Alam Malaysia (SAM)
14. Sarawak Dayak Iban Association (SADIA)
15. Secretariat Ulama Assembly of Asia (SHURA)
16. SOS-Selangor
17. Southeast Asian Council for Food Security & Fair Trade (SEACON)
18. Malaysian Physicians for Social Responsibility
19. Sustainable Development Network (SUSDEN)
20. TERAS Pengupayaan Melayu
21. Third World Network (TWN)
22. Treat Every Environment Special S/B (TrEES)
23. Environmental Protection Society Malaysia (EPSM)
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