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Ties that bind:


Regulatory capture in the country’s GMO approval process

I. Introduction

The Philippines is one of the more GMO-friendly countries of Southeast Asia. Trade and
development of GMO (genetically modified) crops and products is a major part of President
Gloria Macapagal Arroyos’ economic policy. It is number three in the Arroyo Administrations
program for Science and Technology, after Agriculture and Health.

One of the most notable developments in the Macapagal-Arroyo administration’s program of


liberalization in agricultural trade has been the commercialization of GMOs in the country.

In the five years since the creation of the Philippines’ major GMO regulatory bodies, a total of 44
GMO applications have been approved by the government, roughly one approval every one and
a half months. Among the 44 GMOs, four crops were approved for propagation while 40 were
approved for direct use as food, feed and for processing. Most of the approvals, including all four
for propagation, were genetically-altered corn. The rest are for soybean, canola, potato, cotton,
sugar beet and alfalfa.1

Currently, seven more GMOs are up for approval at the Philippines Bureau of Plant Industry
(BPI). These are Roundup Herbicide resistant corn, GMO stacked trait Bt Corn (wherein more
than one trait has been genetically altered), Herculex resistant Bt Corn (for field testing) and
GMO delayed ripening papaya (also for field testing) herbicide resistant rice (LL62) which is
unapproved in most other countries, and Bt eggplant. There are also several GMOs that are
already undergoing “contained” trials but are actually already outside contained greenhouses, in
particular, ringspot virus resistant papaya.

Except for the GMO delayed ripening papaya, all of the approved GMOs, as well as those
currently under review, are products of big multinational agro-chemical companies such as
Monsanto, Syngenta, Pioneer, Bayer, and Dow Agrosciences, all of whom also owns patents to
these crops. And even the GMO papaya with delayed ripening trait, developed by the Institute of
Plant Breeding (IPB) at the University of the Philippines at Los Banos (UPLB) is actually funded
by Cornell University’s Agricultural Biotechnology Support Project (ABSP) II and the United
States Agency for International Development (USAID).

There are more GMO products on their way to approval. BPI and pro-biotech “insiders,” with
reports from Philippine research institutions involved in GMO development, also boast of several
more GMO crops lined up for approval for food, and for greenhouse or field tests. This includes
UPLB GMO crops like Bt eggplant (whose research is funded by Monsanto and USAID), a
multiple virus resistant (MVR) tomato (USAID), GMO mango with a delayed ripening trait (USAID
and Monsanto), and a sweet potato resistant to the feathery mottle virus and weevil (USAID)2.
This is not counting Philippine Rice Research Institute’s research into Golden Rice which has
recently been featured in several news articles3.

1
See Appendix A: Complete List of Approved Applications, As of September 7, 2007 BPI
2
ABSP II Newsletter April 2006; Biolife magazine October- December 2005; and ABSP II Newsletter January 2007
3
"3-in-1" rice country's first GM rice (http://www.pia.gov.ph/?m=12&fi=p070913.htm&no=45); 'Golden rice'
commercial release eyed (http://www.visayandailystar.com/2007/September/19/negor4.htm).

In its 2007 Biotech Report, the United States Global Agricultural Information Network (US GAIN),
noted how the Philippines policy of “acceptance” towards GMOs, could most likely spell an
increase in the number of GMO crops in the Philippine market by 2009, and classified the country
as an “imminent growing net-food importer.”4

The Philippines is now the USA’s 15th largest export market for US agricultural, fishery and
forestry products, many of which are GMOs or made from GMO crops and products. We are also
the USA’s 3rd largest market for soybean meal, 4th for wheat, 5th for dairy products, 6th for snack
foods, and 12th for pet foods. US GAIN estimates that Philippine imports for biotech crops “and
derivative products” at about $400 million.

Indeed, despite continued protest from various Philippine farmers and green groups, the
Philippines is the only Southeast Asian country to allow such a large number of GMO imports
from multinationals, and the only one which has allowed GMO products to enter the country not
only for food, feed, and processing, but which has allowed the commercial propagation of a GMO
food crop as well.

In 2006, a little over four years after the approval of Bt corn for propagation, the Philippines
Bureau of Plant Industry (BPI) reported a two-fold increase in the area planted to Bt corn to
100,000 hectares, from about 50,000 hectares in 2005, and less than 20,000 hectares in 20035.

Greenpeace has noted with growing alarm how the Philippines’ regulatory bodies for GMO crops
have never rejected an application for importation of a GMO from any of the giant GMO
corporations, despite documented cases on questions of their safety and rejection by other
countries, even by countries where they were developed.

Worse, in the five years that the Philippine government has opened its doors to GMO imports and
development, its policy for, and system of regulation and assessment of GMOs for safety (risk
assessment), has remained for the most part closed to the public.

To this day, it is not clear whether the Philippines is capable of truly regulating and assessing a
GMO for safety.

Nor is it clear if the institutions and people in charge of regulation and risk assessment are
qualified to do so. The names and qualifications of the scientists in charge of risk assessment are
hard to come by, and any inquiries on this regard are often met with suspicion and silence.

Even the US GAIN report on “Philippine Biotech Annual 2007” admits, “Nearly 5 years into
regulation…” refinements to the laws and guidelines regulating biotech and biosafety… “are
evolutionary in nature.”

II. Background

This report aims to examine the reasons behind the Department of Agriculture’s continued refusal
to divulge fully to the public its system for approving and regulating GMOs.

4
USGAIN Report Philippines 2007 “USDA Foreign Agricultural Service GAIN Report July 7, 2007 or RP 7046 by
Perfecto Corpuz
5
USGAIN Report Philippines 2007 and BPI report on Bt corn 2004 and 2006. Bt corn 75,000 has., roundup ready
corn 26,000 has., and combined Bt and roundup ready corn 4,000 has.

Why has the Philippines allowed the entry and use of all GMO applications requested by
multinational companies?

Does the Philippine GMO regulatory system truly look after public interests? Is it rightfully biased
in favor of public safety or not?

Why do DA attached agencies refuse to open to scrutiny the names and qualifications of those in
charge of regulation and risk assessment when decisions made by these bodies are bound to
ultimately affect the Filipino public?

Are those in charge qualified to conduct risk assessment, or are there conflicts of interest and/or
vested interest among members of the GMO regulatory bodies?

Does the DA actually have the funds and resources to conduct proper regulation and risk
assessment for GMOs?

It is interesting to note that pro-GMO groups themselves recognize the inherent risks of GMOs. In
a speech delivered in India on 25-27 May 2006, Dr. Benigno Peczon, then president of the
Biotechnology Coalition of the Philippines (BCP), a pro-GMO lobby group, admitted that “since
genetically-modified crops are relatively new and all their effects are not known, a credible
regulatory system must be in place.”6

This is echoed by the Philippine Biotechnology Information Network (BIN) which, along with the
BCP, initiated a program in 2004 to advance an “Integrated Information, Education And
Communication Campaign and Advocacy For Modern Biotechnology”:

All emergency technologies and scientific developments carry risk, among them: (1) the
possibility transgenes will escape from cultivated crops into wild relatives, or (2) the peril of
unintentional introduction of allergens into food; or of (3) pest [sic] becoming resistant,
through time, to the toxins produced by GM crops.

However, legislation and regulatory institutions dictate processes that entail careful review
of applications to precisely avoid or reduce these risks. The technology innovates (i.e.,
scientists), [but] the producers and the government has [sic] the obligation to ensure the
safety of novel food and drugs for people and their benign impact on the environment.7

Ironically, even as the BCP and the BIN themselves acknowledge the all-important role of
government regulatory bodies in assessing GMO risks, their pro-GMO advocacy campaign was,
according to the BIN website, funded by the Department of Agriculture.

However, it cannot be over-stressed that is precisely because the government is a regulatory


body for a technology that is imprecise and carries dangerous risks that the DA cannot be a
cheerleader for GMOs. And members of its regulatory agencies, instead of being partial to, or
connected to, multinational GMO corporations, must exercise bias in favor of farmer interests and
public health and safety.

6
http://www.seedquest.com/News/releases/2006/november/17482.htm
7
Northern Mindanao Consortium for Agriculture and Resources Research and Development (Biotechnology
Information Network) Frequently Asked Questions (http://nomcarrd.norminet.org.ph/biotech_files_new/faqs.htm)

III. Mandates of the National Committee on Biosafety of the Philippines


(NCBP), the DA’s Bureau of Plant Industry (BPI) and Biotech Core Team
(BCT) and the BPI’s Scientific and Technical Review Panel (STRP)

On paper, three institutions are in charge of biosafety, risk assessment, and regulation for all
GMOs that enter the Philippines for contained use (laboratory/experimental use), food, feed and
processing (direct use), and propagation:

1)The National Committee on Biosafety of the Philippines (NCBP) under the Department of
Science and Technology (DOST) with the aid of the Departments of Agriculture (DA),
Environment (DENR) and the Health (DOH);

2) The Department of Agriculture (DA) via the Bureau of Plant Industry’s (BPI) Biotech Core
Team (BCT); and

3) the so-called independent Scientific and Technical Review Panel (STRP).

Created in 1990 by Executive Order 430, the NCBP is supposed to oversee the entire process of
research, risk assessment, regulation and policy for GMOs. In practice, the NCBP delegates
almost all of its functions to Institutional Biosafety Committees or IBC’s (for GMOs applications
that cover lab and field use), and to biotech teams under the Departments of Agriculture,
Environment and Health, (for GMO applications covering Food, Feed, and Propagation or FFP).
Based on track record, it seems the NCBP simply reviews the recommendations of these teams,
and for the most part rubber stamps their findings and decisions.8

When the DA Administrative Order (AO) 8 was issued in 2002, the NCBP handed over the entire
process of risk assessment and regulation of GMO plants and GMO plant products to the
Department of Agriculture via its Bureau of Plant Industry (BPI).

So far, and because almost all questionable GMO products entering the Philippine market have
been food and agricultural products, the real power, it seems, behind GMO risk assessment and
regulation in the Philippines, has been the DA-BPI via its Biotech Core Team (BCT) and the
Scientific and Technical Review Panel (STRP).

Except for GMOs to be used for contained laboratory experiments, the BPI-BCT has been placed
in charge of the review, regulation, and risk assessment of all applications for GMO plants and
GMO plant products to be used as Food, Feed or Propagation (FFP). The BPI-BCT also has the
power to issue or deny a permit for FFP9.

The BCT staff deal directly with the GMO applicant. They make sure all the papers and
documents of an applicant GMO are in place, properly accomplished and handed over to the
NCBP and other DA agencies concerned with regulation, review, and risk assessment.

The BCT, with the help of the DA’s other biotech teams, must also monitor the progress of a
GMO applicant in the laboratory, greenhouse, and fields, and see to it that the applicant has
complied with all requirements for tests and safety.

8
Executive Order 430 1990
9
AO8

However, except for GMO crops undergoing field tests, the BCT is not required to do, nor does it
do, any actual physical monitoring. “Monitoring” for the most part, means periodic interviews with
an applicant, and review of required reports on the progress of a GMO being tested in the
laboratory and greenhouse. Only on occasion, and when it is convenient, does the BCT actually
go to the field. This is also because the 15-person BCT has other duties at the BPI, being part of
the Bureau’s Plant Quarantine Section.10

The BCT, on top of all its other duties, is also in charge of reviewing a GMO for safety or risk
assessment.

It does this by delegating the review to the Bureau of Animal Industry or BAI (who does a partial
review for products destined as feeds), the Bureau of Agriculture and Fisheries Products
Standards or BAFPS (for food safety), the BPI-BCT (for products destined for greenhouse and
field), the Fertilizer and Pesticide Authority or FPA (for “pest protected plants”), and the Scientific
and Technical Review Panel (STRP).11

The STRP’s position is unique. While the BAI, BAFPS, FPA, and BPI-BCT conduct only partial
reviews, the STRP must do a complete paper and desktop review, parallel, and supposedly
independent of the other bureaus and of the BCT.

Thus, the STRP not only evaluates applications for permits for FFP, but must do so with
particular attention to, “the risk assessment and risk management strategies of the applicant and
submit a report to BPI…”.12

The STRP however, does not do any actual laboratory, greenhouse, or field tests to parallel or
verify those done by the applicant. Its only job is to review the scientific and technical
documentation on the GMO and to see that everything in the scientific and technical side is in
order and can be verified by studies here and abroad. Sources from the BPI-BCT and DA
Biotechnology team claim that to do actual lab and greenhouse experiments themselves would
be tantamount to “conflict of interest” and invite bribes from the applicants.

Laboratory and greenhouse experiments are done by the GMO applicant at NCBP “certified”
labs. This means the NCBP simply inspects a lab for qualifications and if it passes inspection,
they issue a permit. The BCT and STRP simply monitor the conduct and review of experiments,
often depending on reports of the applicant.

It is also the STRP that advises the BPI to warn the public of any dangers posed by a GMO
applicant by recommending the “conduct of public hearings by the Institutional Biosafety
Committee…”.13

The STRP's findings on a GMO application carries more weight than the recommendations of the
other bureaus, and is pivotal in the BPI-BCT's decision to issue or deny a permit for FFP, and/or
whether a GMO can be taken off or “delisted” as a regulated article.14

DA AO 8 (2002) first envisioned the STRP as “an advisory body” on GMOs to the Bureau of Plant
Industry, “composed of at least three reputable and independent scientists….to evaluate the

10
AO8
11
AO8
12
DA S.O.384 23 August 2002
13
DA SO 384 23 August 2002
14
AO 8 2002, with SO 384

potential risks of the proposed activity to human health and the environment based on available
scientific and technical information.”15 But DA Special Order 241 (2002) expanded its
membership to include “an independent pool of experts…tapped by the Bureau of Plant Industry
to evaluate the potential risks of the proposed release of GMOs….”.16

The STRP pool is composed of scientists specializing in molecular biology, genetics, plant
breeding, ecology, medicine, veterinary medicine, and nutrition.

But only a committee of three to five members conduct an assessment per application. The BPI-
BCT selects those who will conduct the review and stands as arbiter between the applicant and
STRP.

Once the three-person STRP team finishes its evaluation, it meets with the BPI-BCT, and
together they decide on whether to issue or deny a permit. When neither body can agree on an
application, they call on the Department of Agriculture’s Biotech Advisory Team (BAT) for advice.

The Biotech Advisory Team (BAT) is there to help the DA Secretary decide on Biotech; including
GMO, policies. It is an informal group, composed of representatives from government biotech
regulatory agencies: the DA’s BPI, BAI, FPA; the Department of Environment and Natural
Resources (DENR); the Department of Health (DOH), and the Department of Science and
Technology (DOST).

A pool of scientists and technical experts from various universities and biotech organizations are
also on call to help the BAT. Dr. Benigno Peczon of the Biotechnology Coalition of the
Philippines, along with professors from IPB UPLB like Dr. Evelyn Mae Mendoza, and those from
the National Institute of Molecular Biology and Biotechnology (NIMBB) of UP Diliman, are
members of the BAT. It can be assumed that all members of the BAT are pro-GMO and there is
no representation from contending parties.

In 2003, DA Memo 17 also made it the BAT’s business to advise the DA Secretary, whenever a
GMO applicant appeals a denial of permit by the BCT and STRP. Members of the BCT say that
the BAT can also advise both the BCT and STRP whenever the two bodies cannot agree on an
application.

(See Appendix A for complete GMO regulations.)

IV. “Independent” Biotech Groups

Several so-called “independent” biotech groups play an important part promoting biotech
research and acceptance in the Philippines.

Some play conduits between GMO multinationals and government or state university GMO
research institutions. They make funding available for research and tests on multinational-
sponsored GMO crops (some of which are even up for application with the BPI), in order for the
research to appear independent and free of bias.

15
AO 8 Definition of Terms “STRP”
16
AO 8 2002 and DA Special order 241 (2002) and S.O. 384 August 23, 2002

Others have openly partnered with multinationals and government, to promote GMOs, to water
down any resistance and criticism to GMOs and to lend credibility to government’s shadowy
GMO regulation process and risk assessment.

The Biotech Coalition of the Philippines or BCP is one of the most visible of these groups.
Organized in 2001, at the height of public resistance to GMO Bt corn applications, the BCP has
promoted itself as the partner of government, “academic and scientific communities, industry and
the private sector, farmer associations, media, church and other like-minded civil society
organizations” to steer an “independent but non-confrontational path in biotechnology
advocacy.”17

But BCP’s claims to independence are questionable. Its president, Dr. Nina Barzaga of UP
Manila is an active member of the STRP pool, and is promoting research and use of GMO
vaccines sponsored by multinational GMO corporations. Board members and advisers Dr. Emil
Javier, Dr. Benigno Peczon, Dr. Rhodora Aldemita, have all worked for research institutions who
have partnered with GMO corporations in the research and promotion of GMO crops and
products. Almost all BCP members are scientists from research institutions (including some
active STRP members) who are funded by or have a partnership with multinational GMO
companies.

Among its public relations activities, BCP has organized and sponsored symposia, seminar-
workshops and conferences in schools, local government units and science organizations, to
promote GMOs. It partners with the DA Biotech Program Implementing Unit (BPIU) to help
implement the BIONet program, to “bring government biotech programs down to local
government units… to encourage governors and mayors to ask their farmer constituents to plant
Bt corn, hybrid rice and to be more open to field tests for GMOs.”18

On the other hand, the motives of the International Service for the Acquisition of Agri-biotech
Applications (ISAAA), via its SEAsia Center at the International Rice Research Institute (IRRI) in
Los Banos, couldn’t be clearer. It aims to act as conduit between multinational GMO companies
and government and state research institutions.19 Its partnership projects in the Philippines
include Monsanto corporation’s GMO papaya biotech network, tomato virus diagnostics,
Monsanto’s Bt corn, and IRRI and Rockefeller Foundation’s Vitamin A rice (‘golden rice’). The Ex-
Director of the Institute of Plant Breeding at UPLB, Dr. Randy Hautea, heads ISAAA’s SEAsia
Center. Not surprisingly, Dr. Hautea’s wife heads several UPLB research projects on GMO
papaya and GMO tomato.

Multinational biotech companies have also found their way into several professional scientific
groups, of which several in the STRP are members:

The Philippine Society of Animal Nutritionists (PHILSAN) for instance counts from among its
donor members BASF Philippines, Rhone Poulenc Philippines Inc, Roche Philippines Inc, Union
Ajinomoto Inc, and Diconex Philippines Inc.

PHILSAN via the BCP released an official resolution during the height of the Bt corn controversy,
in support of GMOs and government policies supporting biotechnology, particularly genetic-
engineering.

17
BCP Constitution
18
BPIU forum on BIONet April 2, 2007
19
ISAA in Asia Oct 2000 by GRAIN

The International Life Sciences Institute of Southeast Asia (ILSI SEA) counts several Filipino
scientists as members. ILSI claims to be a non-profit international foundation based in
Washington, established in 1978 to “advance the understanding of scientific issues relating to
nutrition, food safety, toxicology, risk assessment and the environment.” Their advisory panel
come from the National Centre for Food Safety and Technology USA, Unilever UK, Ecolab Inc
USA, Siliker Grp Corp USA. Some of their symposiums include ‘Current and Innovative
Approaches to microbiological Food Safety Management,’ ‘2nd International Conference on East-
West Perspectives on Functional Foods: Science Innovations and Claims,’ and count among
their publications ‘ILSI SEA Region – Monograph on A Guide to Safety Assessment of
Genetically Modified Foods,’ and ‘ASEAN Food Safety Standards Database.’ Their conference
on ‘Nutrigenomics- Opportunities in Asia’ invited guests like Gerard Barry of IRRI who is also
formerly an officer of Monsanto, a major GMO multinational corporation, Laurent Bernard Fay of
Nestle Switzerland, officials from Commonwealth Scientific and Industrial Research Organization
(CSIRO) Australia, William Padolina of IRRI, and Jose Ordovas of the Nutrition and Genomics
Laboratory at USDA.

Even the University of the Philippines National Institute of Molecular Biology and Biotechnology
or BIOTECH (which integrates all biotech departments and services at UPLB) counts
multinational GMO corporations as partners. Not only has UPLB Biotech partnered with the
governments’ Departments of Agriculture and of Science, but with a host of private corporations
and multinationals which include Monsanto and the USAID Program for Biosafety Systems. It
also “networks” with the Biotechnology Coalition of the Philippines, Inc.; Biotechnology
Information Network-SEARCA; and the Biotechnology Association of the Philippines Inc. (BAPI).

V. Conflicts of Interest: Multinational GMO Corporations and the Department


of Agriculture’s BPI-BCT and STRP

While the laws that created and guide all GMO regulatory bodies provide for some kind of
safeguard against conflicts of interest, they are not consistent for all regulatory bodies and do not
make clear whether a law for one body applies to all.

For instance, EO 430 requires that all members of the National Committee on Biosafety Panel
(NCBP) must “not be connected with the organization to be regulated…” and that “no members of
the Committee shall vote in deliberations affecting projects that one serves in as
study/project/program leader, consultant, director, owner of biotechnology projects and/or
ventures falling within purview of the Committee’s concerns.”20

However, AO 8’s only guard against conflict of interest among STRP members is that they be
“composed of at least three reputable and independent scientists who shall not be employees of
the Department [of Agriculture]...”.21

AO 8 has nothing to say on conflict of interest among the BPI-BCT members.

Worse, any stand AO 8 takes against conflict of interest in the STRP is contradicted by a
provision that allows the selection of the STRP review team and even the STRP pool, to become
a “family affair” between the DA Biotechnology Teams and the BPI-BCT:

20
EO 430 1990 Composition of the NCBP
21
DA AO8 2002 Definition of Terms “STRP”

The BPI may tap the services of a STRP to be composed of a pool of scientists who have
the relevant professional background necessary to evaluate the potential risks of the
proposed release of GMOs for field testing, propagation, food, and feed, to human health,
and the environment based on available scientific and technical information.22

Insiders say the DA and BPI often leave the selection of the STRP review team to the BCT. In
fact, the selection of STRP review team members is not as formal as it appears on paper. At
times the selection can be difficult, as many members of the STRP pool are busy and sometimes
beg off work. Insiders add that it is difficult to get qualified scientists to join the STRP as more
and more young scientists choose to work for multinational corporations or go abroad. The BCT
is often forced to use the service of a group of volunteers from the academe, some of whom
have retired or are already deceased.

Compensation for STRP members is small, amounting to about P7,500 per review. It is
interesting to note that some of those who served in the first STRP board in 2002 ended up
working for the multinational corporations with GMO interests. Dr. Violeta Villegas was hired by
Syngenta after a short stint with the STRP, and Dr. Desiree Hautea was awarded research
projects for several GMO projects funded by USAID.

A similar system attends the selection of scientists for the STRP pool. The BCT does this in
consultation with leaders of the BPI, and key personalities of the DA’s Biotech Advisory Team
(BAT), biotech regulatory and policy teams from the other DA Bureaus and the DA Biotech
Program Implementation Unit (BPIU), all of which can be said to be dominated by pro-GMO
members.

Neither does AO 8 define or lay down criteria on what “independent scientists” mean. This has
allowed the STRP to be peopled by scientists from such groups as IRRI, and or research
institutions funded by multinational GMO companies. The STRP pool of June 2003 even included
husband and wife Drs. Fernando and Emiliana Bernardo. The former was then a molecular
biologist at the IRRI, and the latter a Professor at the Department of Entomology at UPLB.

Thirty nine scientists are on the STRP’s active list, most are from the University of the Philippines
at Los Banos, some from UP Diliman and UP Manila. A couple are retired professors. Some are
active in the public relations activities for the DA’s Biotech Program Implementation Unit, and
groups like the BCP.

Some of UPLB's most respected faculty and members of the STRP (inactive and active) are also
members of pro-GMO lobby groups like the USAID-funded Agricultural Biotechnology Support
Project (ABSP), ISAAA, ILSI, Program for Biosafety Systems (PBS), or BCP. Some STRP
members, moreover, are conducting or have taken part in GMO research directly or indirectly
funded by USAID and multinational GMO companies via their schools and institutions. In short,
many of the STRP members have a stake in the GMO industry, in particular research projects
funded by GMO corporations and lobby groups. (See Appendix C for the list of STRP members.)

Dr. Desiree Hautea, Director of UPLB's Institute of Plant Breeding (IPB) was a member of the
STRP in August 2002. While STRP member, she was already conducting research on GMO
crops like rice and corn. Today, she is ABSP II SEA Regional Coordinator and the lead principal
investigator for ABSP II funded projects such as the papaya ringspot virus resistant (PRSV) GMO
papaya and multiple virus resistant (MVR) tomato (where Drs. Filomena Sta. Cruz, Evelyn Mae
T. Mendoza of the Institute of Plant Breeding (IPB), UPLB and Dr. Vermando Aquino are also
22
DA Special Order 241 Series 2002, Creation of the STRP

part of the projects). As mentioned earlier, Dr. Desiree Hautea is the wife of Dr. Randy Hautea,
who used to head the IPB (specializing in legumes) and who is now Director of the SEAsia
Center of the ISAAA.

Ex-IPB Director and active STRP member Dr. Eufemio Rasco, along with former IPB faculty
members Aristotle Burgonio, Dr. Manuel Logrono, Dr. Violeta Villegas and Dr. Eduardo C.
Fernandez, were pivotal in research and testing of Bt Corn for Monsanto and Syngenta
corporations. Burgonio, Logrono, and Fernandez now work for Monsanto.

Dr. Violeta Villegas, STRP member in August 2002, was pivotal in research on Bt corn before its
release. She went on the develop GMO papaya resistant to the papaya ringspot virus (together
with STRP member Dr. Vermando Aquino and Dr. Evelyn Mae Mendoza), and later joined
Syngenta.

Dr. Reynaldo Ebora, active STRP member from UPLB BIOTECH, is Regional Coordinator for
USAID Program Biosafety Systems SEA.

STRP member and abaca expert Dr. Vermando Aquino is one of the DA BPIU’s consultants for
GMO abaca development, so are UPLB scientists in the tomato, papaya and eggplant research
groups funded by ABSP II, and rice, corn and coconut research programs funded by and in
partnership with USAID, Monsanto, and IRRI.

STRP members Dr. Ernelea Cao, Dr. Nina Barzaga and Dr. Eufemio Rasco are also tapped to
help promote DA biotech at BPIU biotech seminars at Universities and Local Government Units.

Almost all STRP members take active part in BCP propaganda drives. STRP member Dr. Nina
Barzaga is BCP president. Many like Dr. Ernelea Cao, Dr. Cynthia Hedreyda, Dr. Ameurfina
Santos, and Dr. Celia Torres Villanueva even contribute to the BCP website and its magazine
Biolife.

Over 80 percent of the STRP pool work with UPLB Biotech and IPB, two institutions that partner
with multinational GMO corporations in the research and promotion of GMO crops and products.

A number of STRP members have been granted permits to conduct GMO research even while
they were still active in the STRP board, or have been allowed to continue GMO research after
having been included as members.

Dr. Fe dela Cueva, STRP member since June 2003, has been conducting research into GMO
banana and sugarcane since 1997. While Dr. Edwin Alcantara, STRP member since June 2006
has been allowed to continue research on the Bacillus thuringensis (Bt). Dr. Vermando Aquino,
STRP member since June 2003, was allowed to continue with his research on GMO sweet
potato and abaca.

Two alternate members of the NCBP are also BCT members. Merle B. Palacpac is co-chair of
the BCT of the BPI while Lorelei Agbagala is a BCT staff member.

Three key officers of the 15 person BPI-Biotech Core Team stand out for their open support of
corporation sponsored GMOs and the GMO lobby organizations that support these multinational
GMO companies. The three have been careful not to sign in as members of any pro-GMO
advocacy group like BCT or ISAAA, but have nevertheless been very active in almost all their

campaigns to promote GMOs developed by corporations such as Bt corn, GM rice, canola,


soybean, cotton, and potato.

As co-chair of the BCT and as chief of the PEQS, Merle B. Palacpac is charged with assessment
and monitoring all laboratory, greenhouse, and field tests of GMO plants/crops. Palacpac was a
key figure in the BPI’s evaluation and decision to allow Bt corn to enter the Philippines for FFP.
Sources say that she is also in charge of the BPI team that is evaluating the GMO Bayer LL62
rice.

Together with Dr. Saturnina Halos, and Dr. Desiree Hautea, Palacpac has shown open support
for USAID funded GMO projects such as the Agricultural Biotechnology Support Project in UPLB
for GMO papaya, eggplant, and tomato. In 2006 she was recognized by Pioneer Hi-Breed, a
giant agri-biotech corporation, for her “invaluable contribution to the promotion of Biotech” in the
Philippines, along with BCP’s Drs. Benigno Peczon, Saturnina Halos, Randy Hautea (ISAAA) and
Evelyn Mae Tecson-Mendoza (Biotech, UPLB).

Vivencio R. Mamaril is vice chair of the BCT and Supervising Agriculturist at BPI. He was former
Chief of the BPI's Plant Pathology Section, headed its Secretariat on Plant Variety Protection and
is Executive Assistant of its National Seed Inspection Committee. He is also a member of
BIOTECH Core Inc., a US based GMO research company that services several multinational
GMO corporations in pharmaceuticals and industry.

Like Palacpac, Mamaril was part of the team that assessed, and gave the go signal for, the GMO
Bt corn for approval for FFP. He is active in promoting GMOs via events promoted by the BCP
and ISAAA. He also contributes articles on GMO risk assessment and the safety of Bt corn to
BCP’s magazine Biolife.

Thelma Soriano is head of the BCP Secretariat and a Senior Agriculturist at the BPI. She
oversees the paper work for applications, biosafety and risk assessment documentation for
applicant GMOs. Of all BCT members, it is Soriano and her staff of one, who deal directly with
GMO applicants on a day to day basis, and act as go-betweens the applicant, the STRP, and
other BCT members. (STRP members, specially those chosen to review an application, are not
allowed to talk to applicants).

Soriano has written several PR papers and has given talks defending the BPI’s system of risk
assessment. Like Palacpac and Mamaril, she is careful not to sign in as a member of groups like
BCP, but is active in most of their public relations activities.

(See Appendix B for the list of members of the Department of Agriculture - Biotech Core Team)

The influence of multinational GMO corporations can also be seen in the make up of the
Department of Agriculture’s Biotech Advisory Team (BAT), and Biotechnology Program
Implementing Unit (BPIU). Members of both these agencies take part in many pro-GMO public
relations activities, including forums and symposia, and defend the government’s GMO programs
in print, radio, media and internet. They do this even while they exercise an advisory capacity on
GMO regulatory processes.

Dr. Saturnina Halos is the current chair of the Biotech Advisory Team and Head Advisory Unit
DA. Along with BPIU's Alice Ilaga, Dr. Halos is an aggressive defender of GMOs. She plays a big
part of the Biotech Coalition of the Philippines’ promotional symposia, along with BCP and STRP
member Dr. Nina Barzaga, and BCT founder Dr. Benigno Peczon. Along with husband Dr.

Ponciano Halos, Dr. Saturnino Halos is also owner of Arnichem, manufacturer of bio-fertilizer
Vital N. She was signatory to the BCP’s call for support for the GMO Bt corn and for GMOs and
in 2006 was honored by Pioneer Hi-Breed, a multinational GMO corporation, for “pushing the
frontiers of the corn industry and biotech” (along with STRP member Nina Barzaga, Samuel C.
Dalmacio, Dr. Randy A. Hautea and husband Dr. Ponciano M. Halos).

Alice Ilaga is Director Biotechnology Program Implementation Unit. She was formerly
Biotechnology Program Director, US Department of Agriculture and director of its Biotechnology
Unit. The BPIU oversees the DA’s Agricultural and Fisheries Biotech Program under the US Food
for Aid Programs’ PL480. Ilaga is tasked to help implement, coordinate, and defend government’s
biotech/GMO program, and to rally the support of local government units, farmers, businessmen
and professionals behind it.23 The BPIU then is the channel by which multinational GMO
corporations can spread pro-GMO propaganda through a government agency thus legitimizing
the close cooperation between GMO regulatory bodies and the GMO lobby groups controlled by
agri-GMO corporations.

In 2004, BPIU together with Biotechnology for Life Media and Advocacy Resource Center
(BMARC, a pro-GMO public relations machinery), the BCP, SEARCA (Southeast Asia Regional
Center for Graduate Study and Research in Agriculture) and PCCARD (Philippine Council for
Agriculture, Forestry and Natural Resources Research and Development), formed the BIONet
Program. BIONet’s aim is to bring government biotech programs down to local government units.
BIONet holds education seminars among local government units to encourage governors and
mayors to ask their farmer constituents to plant Bt corn, hybrid rice and to be more open to field
tests for GMOs. They help the LGUs and farmers contact biotech centers like Agricultural
Biotechnology Center at Philrice. This year BPIU also launched their “LGU Course on
Biotechnology” with the same aims as BIONet. STRP members Drs. Ernelea Cao, Nina Barzaga,
Eufemio Rasco, are often on the road with Dr. Saturnina Halos and Alice Ilaga to promote BPIU
projects.

Ilaga deals directly with companies and scientists who want to implement GMO projects and
businesses in partnership with government. BPIU also taps into the services of GMO experts
from the UPLB and research institutions like IRRI.

Even while Ilaga promotes GMOs, as part of DA-BPIU, she is also part of the BAT pool. And as
such, like Dr. Halos, she is on call to advise the DA Secretary on biotech policy, update him on
developments in governments’ biotech programs, and give advice on appeals filed by GMO
applicants denied permits by the BCT and STRP.

VI. Budgets for GMO regulation

For all the hype GMOs get from government, the budget for GMO risk assessment and regulation
is small and has been shrinking.

In 1991, a year after the NCBP was founded, its budget stood at PhP 539,000.00. In 2002, the
year AO 8 gave crop regulation to the BPI, NCBP budget had shrunk to PhP 351,000.00 and in
2005 it went even lower to PhP 169,000.00. Even the 2007 recommended budget is small
compared to 1991, at PhP 482,000.00.

23
DA AO 35 series of 2000 Creation of a project implementation unit for the Philippines agriculture and fisheries
biotechnology program under the pl480 fund

The BPI-BCT which includes the STRP (“enforcement of commodity and plant quarantine laws,
rules and regulations”) started with a budget at PhP 2,635,000.00. In less than a year by 2003
the budget was down to PhP 2,346,000.00, and did not change in 2005. This 2007, the General
Appropriations Act recommends PhP 2,437,000.00, a little more than that of 2005 but still less
than what they had in 2002. It is important to note that this budget is not solely for the BCT alone,
but for the BPI's entire regulatory and quarantine service.

A study on Biotech Regulation and Environmental Risk Assessment24 found out that government
saved money on GMO regulation, safety and risk assessment, by having qualified staff do risk
assessment and regulation on a part time basis. This way, their main agencies paid for their
salaries and operational costs. The BCT for example, is actually part of the BPI’s Plant
Quarantine Section. Only the BCT Secretariat (a total of two people) work full time on risk
assessment. The BAI, BAFPS, FPA biotech teams are also made up of people with other jobs in
their respective agencies, and are pulled out according to availability.

The salary at BPI is small compared to private companies. A director at the BPI gets only PhP
24,000.00 per month as basic pay, with an allowance of PhP 8,000.00. Technical staff receive
about PhP 11,000.00 to PhP 22,000.00 per month, and an allowance of about PhP 2,000.00 to
PhP 6,000.00

NCBP, IBC, and STRP members also do risk assessment on a part time basis. Inside sources
say that NCBP members receive only a monthly travel allowance of PhP 2000.00, while STRP
members are paid only PhP 6,000.00, and now increased to PhP 7,500.00 per review.

The small budget for regulation explains why the BPI, BCT, and STRP can only do a paper or
desk review. Government cannot pay for anything more.

This also explains why laboratory and greenhouse tests are done in NCBP “certified” labs.
Sources at BPI say they cannot possibly do all the tests given their equipment.

This lack of budget may be seen to open the system and its regulators to much temptation. If not
to outright bribes, then to rewards in the form of study and research grants, or jobs.

VII. Conclusion

Given the above, the Philippine government’s seriousness about the assessment of the risks
which GMO proponents themselves admit are inherent to GMOs, is highly questionable.

There is conflict of interest and vested interest among members of the regulatory bodies to favor
most of the GMO applications:

• most members of these regulatory bodies are also members of the pro-GMO groups such
as the Biotech Coalition of the Philippines, and/or support BCT MEANING, ISAAA, and
Croplife (a consortium of agri-biotech companies), and their activities in the Philippines;
• many come from universities, or government departments and institutions who have
partnered with USAID, ABSP II, BCP, ISAAA and Croplife in research projects, and in
activities aimed at ‘selling’ GMOs as safe;
24
Linda Penalba, John Fajardo et al, March 2006 Inst. of Agrarian and Urban Devpt. Studies, College of Public
Affairs, UPLB

• some active members of the STRP and GMO/biotech teams of the Department of
Agriculture have applied for and have been granted permits to conduct GMO projects by
colleagues in the BPI and STRP, or are in the process of applying for permits; and
• identities and CV’s of key regulatory bodies in the IBC, STRP, and the DA BCT and BAT
are not made open to the public, making conflict of interest easy to hide.

The system by which the members of the regulatory bodies are selected also allows for conflict of
interest and vested interests, mostly in favor of the company or the scientist applying for a permit.
Nothing in the Laws (EO 430 or AO 8) specifies what constitutes the ‘independence’ of its
members or officers.

Moreover, the system by which these regulatory bodies conduct risk assessment is fraught with
conflict of interest, while the laws that govern and guide the system either contradict each other
or ignore guidelines previously set. The system for biosafety and risk assessment:

• seems to have been crafted more to make assessment more ‘cost effective’ and attune to
the government’s lack of funds and personnel than to actually check for safety; and
• also leaves the general public ignorant of the GMO in question, and, worse, open to,
instead of protected from, the dangers posed by GMOs.

In short, the system which was established to protect the public health and the environment, is on
the contrary, protecting the interests of GMO multinational corporations in their quest for new
markets and profit above all. The regulatory bodies (NCBP, the BPI, BCT and the STRP) have
been occupied by the same group of scientists who have also represented big multinational
interests throughout their careers. Risk assessment, as it is in the Philippines is nothing more
than a means by which a small group of scientists and government bureaucrats conspire to help
multinationals agricultural corporations and big interest groups gain a further, and firmer foothold
in Philippine agriculture, by bringing in their GMO crops, products, and technology.

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