October 9, 2014
Philip Malmberg, CEO
Malle, 2390 Belgium
Dear Mr. Malmberg:
We are writing you on behalf of environmental, food, consumer, health, small-farmer, economic-justice and other civil society organizations, some of which were involved in raising concerns earlier this year about Ecover’s planned use of synthetic biology-derived algal oil. In the last few weeks, some of us have been contacted to participate in roundtable discussions, sponsored by Solazyme. We do not believe that the organization, framing, and details of these roundtables are appropriate to address the concerns we initially raised with your company. We are writing to express our concerns about the roundtable process and to suggest an alternative, more productive path in addressing the numerous problems and questions surrounding this product of synthetic biology.
In response to public concerns about Ecover’s proposed use of synbio-derived algal oil, Ecover announced in mid-June that it would delay its use of this ingredient in its products for six months, during which time it would engage with stakeholders about their concerns, including civil society groups. We understood that this process would be initiated by Ecover to consider these issues and concerns and make a decision about whether or not to use synbio-derived algal oil.
We were later told that Ecover “is leading a multi-stakeholder round table to share information and define guidelines for the responsible and sustainable use of ingredients that employ bio-technology.” We urged your company to drop the assumption that synthetic biology could be responsibly commercialized in absence of adequate mandatory oversight, safety assessment and labels and without a full understanding of its impacts on our health, communities and our environment. We also asked your company to address the more fundamental question of whether – not how – it should be used in Ecover’s products.
However, this process has seemingly changed course once again. We have learned that Solazyme, not Ecover, will be convening a multi-stakeholder dialogue, and that Ecover would merely be one of the participants. We now understand that this dialogue will be managed by both The Robertsbridge Group and Future 500. According to one invitation to one of these roundtables, the discussions will address Solazyme’s own “operations and aims.”
The invitation indicates that the goal of these conversations is to help Solazyme develop “gold standard” practices for trying to both responsibly and sustainably proceed with its current rapid commercialization of products derived from biotechnology, including synthetic biology. It is now not clear how this will inform Ecover’s process of deciding whether it will press ahead with using ingredients derived from synthetic biology.
We have major concerns about this process as it is now proceeding:
The wrong sponsor:
First, we are uncomfortable that ownership of this process has now been passed from Ecover to Solazyme. It introduces a clear, inherent conflict of interest and bias to have the biotechnology company that produces the controversial ingredient take Ecover’s place as the principal mover of the dialogue. We do not feel it is appropriate for Solazyme to frame discussions, given the high financial stakes for this company.
We would have been interested in an open discussion convened by Ecover to determine whether or not it is truly sustainable for your company, which positions itself as a sustainability leader that sells natural products, to use synthetically bioengineered ingredients. It is Ecover’s consumer products and reputation that are at issue and it is Ecover that can choose to formulate in other ways consistent with its brand (e.g. with sustainably produced coconut oil).
Instead, the roundtables seem to be primarily designed to help Solazyme, a company already deeply committed to using the various extreme forms of biotechnology, including synthetic biology. Solazyme says that it wants to develop a “gold standard” in “responsible use” of its technologies. This is distinct from Ecover’s initial commitment, and we’re sorry to see Ecover abdicate its responsibilities as a leader in the green products industry in this way.
The wrong question:
Second, the roundtables as now proposed are based on the false presumption that synthetic biology can be responsibly commercialized at this time. Solazyme’s own website states: “We strive to set the gold standard for rapid, responsible and sustainable development of technology and products.” And letters from Robertsbridge also refer to helping Solazyme develop this so-called “gold standard.” This presumption that synthetic biology can be both rapidly and responsibly commercialized is now built into framing of the proposed roundtable process. The focus is not on exploring whether synthetic biology should be used but only how.
In fact, research suggests that synthetic biology is far from being at a point where it can be responsibly used in commerce or released. For example, in May, 2014, the Woodrow Wilson Center and the Massachusetts Institute of Technology released a report which outlines some of the major unanswered ecological questions about synthetic biology. The report was funded by the U.S. National Science Foundation. It’s a list of serious questions about ecological risks, including irreversible impacts. Actually funding, conducting and analyzing the research and application of the results is all in the future. (See http://www.wilsoncenter.org/article/ecological-risk-research-agenda-for-synthetic-biology).
Also, as we write, 193 countries at the UN Convention on Biological Diversity are debating whether to place a moratorium on the field of synthetic biology, with many governments alarmed by the lack of oversight and regulation for such a powerful technology. That body has already urged nation states to take utmost precaution when handling this technology. In our view, that is incompatible with “rapid commercialization.”
The wrong timing:
We are also alarmed that the proposed roundtable process invitations were sent with such little notice, with little regard for commitments, resource constraints, and other commitments of the non-profit organizations being invited. A handful of organizations were contacted at the end of September for a meeting in London in mid October regarding an issue that was first raised back in April. If this discussion is a priority for Solazyme and Ecover, more notice is respectful.
The wrong stakeholders:
While we appreciate that a couple of the groups who signed the open letter to Ecover on the question of synthetic biology have been invited (at very late notice), some of the most obvious stakeholders are not being engaged. For example, replacing coconut and palm-derived ingredients with sugar-derived algal oil will most affect coconut farmers in countries such as the Philippines, and sugar workers in Brazil. A meeting with a few representatives of big environmental groups does not stack up to proper consultation with affected stakeholders, including ecologists. Fair representation of those with most at stake would also require proper resources to support their participation.
Another wrong convener:
We understand that Ecover has contracted with Forum for the Future to carry out conversations with a range of stakeholders to explore “what would be needed” for synthetic biology to “be part of a sustainable future.” Similar to our concerns expressed above, if this discussion is to inform Ecover’s decision about using ingredients derived from synthetic biology, we also believe that Forum for the Future, while much respected, is not a neutral convener on this topic. Forum for the Future has been contracted by the Industrial Biotechnology Leadership Forum to develop reports in favor of using biotechnology in industrial processes (including synthetic biology). The founder of Forum for the Future, whose name is associated with those reports, has declared himself (and Forum) “a real enthusiast” for these technologies.
A proposal for a new, transparent and open process:
We do appreciate Ecover’s interest in proceeding responsibly on this matter and take your sincerity as a given. For that reason, we ask that Ecover return to its original commitment, and consider working with us to develop a fair and trustworthy process to ask whether synthetic biology can be used sustainably or responsibly at this time, and whether it should be used commercially by Ecover. That could help restore trust in Ecover among civil society, concerned scientists, and consumers. It could also prove a pivotal moment in our mutual efforts to align the public interest with decisions about powerful emerging technologies. We look forward to your response to our proposal.
Colleen Cordes, Director of Outreach and Development – The Nature Institute (USA)
Florent Compain, Head – Amis de la Terre France (France)
Jaydee Hanson, Senior Policy Analyst – Center for Food Safety (USA)
Maria José Guazzelli, Executive Director – Centro Ecológico (Brazil)
Nina Holland, Campaigner – Corporate Europe Observatory (Europe)
Helena Paul, Co-Director – EcoNexus (UK)
Jim Thomas, Programme Director – ETC Group (International)
Kerstin Lindgren, Campaign Director – Fair World Project (USA)
Dana Perls, Food and Biotechnology Campaigner – Friends of the Earth (USA)
Wenonah Hauter, Executive Director – Food & Water Watch (USA)
Jonathan Matthews, Founder and Campaigner – GMWatch (UK)
Devlin Kuyek, Senior Researcher – GRAIN (International)
John W. Roulac, President and Chair – Nutiva Nourish Foundation; CEO and Founder – Nutiva (USA)
Ronnie Cummins, National Director – Organic Consumers Association (USA)
Ana Meirelles, Coordination Representative – Rede Ecovida de Agroecologia (Brazil)
Chee Yoke Ling, Director of Programmes – Third World Network (International)
Winfridus Overbeek, Coordinator, International Secretariat – World Rainforest Movement (International)
Jonathan S. Wolfson, Co-founder and CEO, Solazyme, Inc.
Jill Kauffman Johnson, Solazyme, Inc.
Dirk Develter, Ecover
Tom Domen, Ecover
Charles Secrett, The Robertsbridge Group
Bill Shireman, Future 500
Brent Tarnow, Future 500
Jonathon Porritt, Forum for the Future
Anna Warrington, Forum for the Future