Statement on the Bio safety and Biotechnology Bill 2012
Food Rights Alliance (FRA)
20 February 2013
Submission to the Parliamentary Committee on Science and Technology
We, the members of the Food Rights Alliance (FRA), an alliance over 60
international, national and community based organisations and individuals are writing
to express our views and opinions on the proposed national law on Biosafety and
Biotechnology (2012 Draft). FRA spearheaded by Southern and Eastern African
Trade Information and Negotiations Institute-Uganda (SEATINI-Uganda) and
Participatory Ecological Land Use Management-Uganda appreciates the efforts by
Government for developing and putting in place a National Biotechnology and Bio
safety policy (2008), to guide and ensure the safe development and application of
tools of modern biotechnology.
We thank the parliamentary committee on science and technology for giving us the
opportunity to make our submission in regard to the Bio safety and Biotechnology Bill
2012
We understand that the application of the bill is on research and general release of a
Genetically Modified Organisms (GMOs) and one of the objectives of the bill is to
facilitate the safe development and application of biotechnology. We also understand
that certain parties are looking to pass this bill into law as soon as is possible. It is for
this reason that parliament has called for submissions, and we feel compelled to
respond.
Concerns on GMOs
First, we wish to share our concerns about GMOs in regard to agriculture, the
environment and our economy.





GMOs will bring high costs to farmers because the seeds are patented by the
corporations that sell them. Patented seeds mean that seed saving is
forbidden and we must buy new seeds each season. Many Ugandan
farmers, especially small-scale farmers, will be unable to bear the additional
cost of buying expensive patented seed each season.
Some GMOs have had genes from different species put into them. They are
new and potentially unsafe. There could be unknown health risks associated
with inserting genes from different species into our food
There is a risk of contamination of our indigenous crops from fields planted
with GMOs, through the likely event of cross-pollination.
We are also aware that in other countries such as Canada and the US,
farmers have been sued by the corporations for saving their GM seed, or for
being accidentally contaminated with GM genes through cross-pollination.
If seed saving is forbidden, future generations will lose the knowledge of
natural and traditional seed and its value.
1




We fear that contamination of our agriculture and seed with GMOs will mean
the loss of export markets to countries that have already rejected GM foods.
GMOs will lead to the perpetual enslavement of small farmers by
corporations, by controlling all the seed and forcing us to buy on their terms,
season upon season.
GMOs do not address the real problems of food insecurity in Uganda. They
are only serving to distract policy makers from the good options that already
exist, which are being underutilized.
The process of developing GMOs also provides scientists with an opportunity
to produce sterile seeds. The idea of producing sterile seeds disrespects
farmers’ rights to seed and causes total dependence of farmers and
generations to come on corporations.
General Concerns on the Biosafety and Biotechnology Bill 2012
We are concerned that;
The bill fully accords the Uganda National Council for Science and Technology
(UNSCT) with the mandate to approve confined field testing, export, import or transit.
Whereas the UNSCT is the competent authority on matters of Science and
Technology, we feel the final approval for commercial release of GMOs, export,
transit and import should lay with a government ministry preferably the Ministry of
Agriculture, Animal Industry and Fisheries. Refer to Part II Section 7 (1 (a)
The bill does not provide for labelling of GMOs especially for general release on the
market. Labelling is very important to especially observe consumer rights. The Bill
should give powers to the minister in consultation with the competent authority to
develop regulations regarding packaging and labelling of the GMOs before being put
on the market.
There is no risk assessment report required for importation of GMOs. This is very
critical to avoid an influx of unsafe GMOs from other countries. Refer to Part III
Section 23
There is a very sketchy provision for public participation and consultations during the
development and general release of GMOs. We propose that separate provisions on
public consultations are developed as part of the miscellaneous provisions.
Uganda’s agricultural sector is mainly composed of small holder farmers however
there is no clear mention of representation of the small holder farmers in the bill.
There are no specific provisions on conflict of interest whereas there are number of
provisions in the bill that need this. Specific provisions are needed especially in
regard to the roles of the Institutional Biosafety Committees, National Biosafety
Committee and the Uganda National Council for Science and Technology. Refer to
Part II Section 9 and 14 (6)(a)
There are a number of key definitions search as ‘unintentional release’, ‘bioethical’
and ‘benefit sharing’ that are missed out in the interpretation. For enforcement
purposes all key terms need to be clearly interpreted. Refer to Part I section 3
Conclusions
2
The biotechnology and bio safety bill 2012 draft seems to hold no respect for the
rights of the farmers and if farmer’s fields are contaminated by GMOs it will be
impossible for them to successfully claim for compensation. The bill does not have
provisions for communities to claim for compensation where their environment or
food is contaminated by GMOs.
We highly commend the efforts by the Government of Uganda to advance
biotechnology development especially in agriculture however; this should not be
done at the expense of the farmers and general public in Uganda. We call on to the
government to respect farmers’ rights, food security, seed diversity and traditional
cultures.
Members of Food Rights Alliance
1. Abantu for Development
2. Action AID International Uganda (AAIU)
3. Advocates Coalition for Development and Environment ACODE
4. African Centre for Trade and Development (ACTADE)
5. African Women Economic Empowerment Network (AWEPON)
6. APSD
7. Ankole Food Security Network
8. CAD Uganda
9. CARITAS Uganda
10. Consumer Education Trust (CONSENT)
11. Development Network of Indigenous Volunteers Association (DENIVA)
12. Eastern Uganda Food Security Network
13. Environmental Alert
14. Historic Resources Conservation Initiatives
15. Kabalore Uganda Food Security Network
16. Northern Uganda Food security Network (NUFOSEN)
17. Southern and Eastern African Trade Information and Negotiations Institute
(SEATINI-U)
18. Uganda Consumers Protection Association (UCPA)
19. Uganda National Farmers Federation (UNFFE)
20. VECO Uganda
21. VEDCO, Uganda
22. Youth Plus Uganda
23. Centre for Development Initiatives (CDI)
24. Pallisa Civil Society Network (PACONET)
25. Mbarara district Civil Society Forum
26. National Hunger Task Force
3
27. Plan International Uganda
28. Pro Biodiversity Conservationists in Uganda
29. Uganda Women Organizations Network (UWONET)
30. Masindi Seed and Grain Ltd
31. Food talk Uganda
32. NACHWOLA
33. Hunger fighters
34. CODI
35. SOBUDEA
36. SEDFA
37. MPIFA
38. Participatory Ecological Land Use Management (PELUM-U)
39. Masaka District Farmers Association
40. Uganda Environment Education Fund (UEEF)
41. Mityana Mubende District Framers Association
42. TAF Assured Uganda
43. Hope Against Poverty
44. IFDI
45. Center for Participatory Research and Development (CEPARD)
46. Center for Health Human Rights and Development (CEHURD)
47. National Association of Women in Uganda (NAWOU)
48. Agency For Integrated Rural Development (AFIRD)
49. GORTA Uganda
50. East and Southern Africa Farmers Forum (ESAFF-U)
51. Uganda Debt Network
52. Concern Worldwide Uganda
53. Uganda Land Alliance
54. Arua District NGO Forum
55. CLEAR UGANDA
56. GREEN NATURE GROUP
57. KIKANDWA ENVIROMENTAL ASSOCIATION (KEA)
58. NAPE
59. Pastoralist and Poverty Frontier (PPF)
60. Rural Development Media and Communication (RUDMEC)
61. TROCAIRE
62. U-CAN
63. WAR ON WANT (WOW)
4
64. World Vision Uganda
65. YOUTH ALIVE UGANDA
5