8 April email from CTNBio member Paulo Paes de Andrade regarding Approval of GE Eucalyptus Trees in Brazil

(Response to Mr. Andrade from Winnie Overbeek and Dr. Ricarda Steinbrecher, members of the Steering Committee of the Campaign to STOP GE Trees below)

Dear Mrs. Petermann.

I can understand that the commercial release of the first transgenic tree in the World may be surrounded by a cloud of worries, derived from different risk perceptions. However, decisions have to be taken on the basis of risk assessment, not on risk perceptions. That is the duty of CTNBio, the Brazilian GMO regulatory agency. The agency has thoroughly evaluated this GM event and came to the conclusion it is safe. Indeed, the GM eucalyptus is far from been a dangerous organism, as frequently presented by some groups, especially in Brazil:

  1. a) it is not native from our country;
  2. b) it does not cross with any plant in Brazil, except with Eucalyptus itself;
  3. c) eucalyptus are very seldom propagated by seeds nowadays;
  4. d) the general agronomic characteristics of the GM eucalyptus are very similar, if not identical, to the non transformed variety. It will not behave as a vicious water sponge.
  5. e) seeds, if produced, are not usually by animals and pollination is effectively restricted to less than 600 m
  6. g) pollen is proved to be innocuous to bees (both Apis and other native species)

h)Brazil does not export seeds or eucalyptus products containing seeds.

Taken this information in account, as well as the large set of data derived from field and lab experiments, and following the regular risk assessment procedure, the Commission evaluated all concerns (or dangers) derived from the risk perception of different actors in the complex Brazilian GMO scenario. As already said, it correctly concluded the product is safe.

Please bear in mind that trade issues, as well as coexistence of different productive chains, are not the subject of CTNBio: similarly to EFSA or the OGTR, CTNBio only evaluates the direct (biological) risks of a GMO release.

Also bear in mind that all considerations concerning biosafety issues brought into discussion by the Cartagena Protocol have also been discussed at CTNBio. Trans-boundary movement of transgenic eucalyptus plantlets or seeds is highly improbable and accidental seed propagation elsewhere is even more improbable. Therefore, the release of this GM tree is solely a Brazilian question and no other country or group of countries has the right to interfere in our decision.

Please find enclosed a short risk assessment of this GM eucalyptus in Portuguese. I am convinced that, before engaging in such an international effort to block a technology that will find large use in my country, you and the thousands that signed the petition should get the attached text translated to English and have a good reading of it. Information is the key to right decisions and, as the Germans say, wer nichts weiss muss alles glauben.

Prof. Dr. Paulo Paes de Andrade

Laboratory of Molecular Genetics

Departmento de Genética/ Universidade Federal de Pernambuc

Recife  PE   Brasil

H421 Eucalyptus risk assessment – short – Portuguese

Response from Winnie Overbeek:

– if the CTNBio is doing its assessments and decision-taking ‘correctly’ , how does Mr Andrade explain the written complaint, signed by a public prosecutoron April 8th, from the National Forum to combat the impacts of Agrotoxins about very serious concerns with how the CTNBio has been doing its work, e.g. the systematic failure of respecting the Brazilian Biosafety Policy by the CTNBio?

– If the work of the CTNbio is so correct, then why is Brazil now number one in the world in ´consumption´ of agrotoxins – many of which linked to the GE crops that were released  by the CTNBio and are now planted in the country? The Brazilian agrotoxin consumption is about 6 liters per person per year, remembering there are about 200 million Brazilians! This is why peasants (most affected by this massive use of agrotoxins) and others groups in Brazil are so angry and desperate with this model based on agrotoxins, and formed a National Campaign;  many many thousands of peasants have died in silence, without being news. Many still are dying because of this huge amount of agrotoxins applied, that benefits  transnational companies in the first place;

– and last but not least, national borders in many countries in the world have been established by the dominant class at some point in a history marked by colonialism but they will never impede our solidarity actions that have no borders. It is actually an obligation for anyone to show solidarity with anyone else, whereever violations of any type or dangerous threats for that are taking place, such as this CTNBio approval of GM eucalyptus trees.

Response from Ricarda Steinbrecher of EcoNexus:

Regarding Mr. Andrade’s German quotation “wer nichts weiss muss alles glauben” (he who doesn’t know anything must believe everything) – I think the following is more applicable to his statement: “wer glaubt, alles zu wissen, muss noch viel lernen” (he who believes he knows everything still has to learn a lot”.



  1. Paulo Paes de Andrde says

    Dear readers, just a small correction: I was a CTNBio member until September 2012. I am still interested in risk assesment and closely folloow CTNBio evaluations.

  2. Drew Kershen says

    CTNBio deserves praise for focusing on the risk assessment of genetically-modified eucalyptus. By focusing on risk assessment, CTNBio has stayed within its legitimate function. In addition, by the thoroughness of its risk assessment, CTNBio has allowed Brazil to gain access to the benefits of this particular eucalyptus variety and has allowed Brazilian society to benefit from advances in science and breeding. Congratulations to CTNBio.

  3. Lucia de Souza says

    Thanks Prof. Paulo Andrade for your thoughtful explanation. I would add to your comments that besides the fact that the new eucalyptus is not dangerous according to evidence based risk analysis. It’s faster growth and reduced lignin content is likely to bring ecological benefits to our country. Growing faster or increasing yield means that less forest will be cut down to produce the same amount of wood. In addition, reducing the need of nasty chemicals for the pulp extraction is also a environmental benefit.

  4. Paulo Andrade says

    Dear Mrs. Overbeek, dear Dr. Steinbrecher, thanks for your considerations. Please find below my answers to them, which I hope will help in the understanding of the missions of CTNBio and of the complex Brazilian agronomic scenario.

    Some groups and individuals believe CTNBio should include pesticides in its risk assessment. The prosecutor, who is very active in the fight against the indiscriminate use of such chemicals, is one to mix CTNBio´s mission to that of ANVISA. CTNBio sole mission is to access the direct biological risks of GMOs.

    The Brazilian agriculture in fact uses a lot of pesticides, even more than the USA, if we consider its smaller crop area. From the 160 million hectares of agricultural land, only 42 million are planted with GM crops, but pesticides are used in all crops, irrespective of being GM or not. The most used pesticide is glyphosate, but it was already massively used before the adoption of agribiotechnology and the general pattern of the different pesticides uses did not change significantly after the large adoption of GM crops. The reason why we use lots of pesticides is double:

    a) Brazil has a very intensive agriculture for almost every relevant plant (rice, oranges, beans, potatoes, sugar cane, coconut, eucalyptus and, obviously, soybeans, maize and cotton, the only GM crops presently). This implies the use of pesticides, but by no means of just those used in GM crops: there is a large use of other herbicides besides glyphosate, fungicides, insecticides, nematocides, etc. Moreover, as I said before, glyphosate is the most used pesticide well before the use of GM crops in Brazil and the same is true around the World.

    b) The Brazilian climate is warm and rainy. This situation demands much more herbicides than what is seen in USA.
    In spite of the large use of pesticides, the amount of acute intoxications is relatively low: 5000 per year, from which a half is due to suicide attempts. As for food born intoxications, it never surpasses 10 per year. These are official data from SINITOX, which are coherent to what is seen in other official databanks and in the medical practice. There is such a thing as “many thousands of peasants dying in silence”: my country is not a blind dictatorship and the social control of every activity is pretty much as large as in any other modern, civilized country.

    The data above supports the idea that, despite their large use, humans are not usually exposed to them, or at least not exposed to doses beyond the accepted levels, except in some occupational cases (possible related to unconformities in pesticide use). The result of the division of the total amount of pesticides by the total Brazilian population is a simplistic and not much informative number.

    As for the concern of National borders, I completely agree that this must be taken into account. As a Party of the Cartagena Protocol, Brazil did seriously consider that question in relation to the GM eucalyptus. Please keep in mind that the GM eucalyptus plantations will certainly lay many hundreds of miles apart from any Brazilian borders, as the best areas for this crop are in the east coast, north from Paraná. Propagules are not expected to cross borders and even if they do so, it is highly improbable that they can be further propagated in another country without the direct help of humans.

    Finally, I agree with Dr. Steinbrecher´s rewriting of the original motto: wer nichts weiss, muss alles glauben. Indeed, those who think they know everything are equally prone to be criticized. As scientists (even those wearing the had of risk assessors), we should try to be in a position of openness, being ready to review concepts and to change minds whenever the proper scientific arguments are brought into discussion. I am far of being sure I know everything and I am open to hear and consider arguments based on scientific appraisals of LMO risk assessment.

    Kindly, PPA