Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Memorandum submitted by SCIMAC (D2)

1.   SCIMAC view of the current state of the public debate on GM crops and foods, and whether the Government is taking enough of a role in promoting and moving the debate forward.

  As the vehicle for presenting and mirroring the public debate, much of the media hysteria which surrounded the issue two or three years ago appears to have subsided. If media interest can be taken as a barometer of controversy or public concern, successive announcements of each new round of plantings with the Farm-Scale Evaluations have attracted less and less media attention, particularly at a national level.

  From a regulatory perspective, public debate and consultation continues on a number of fronts—in relation to the implementation of new EU rules for the approval of GMOs for environmental release, for example, as well as future requirements for seed purity and the traceability and labelling of GM products.

  In SCIMAC's view, the Government does have an important role within that debate which it must not neglect. Clearly, issues of public and consumer attitudes towards GM crops and foods are the preserve of commercial and market forces, not the responsibility or concern of regulators.

  It is, however, the responsibility of Government to provide clear, transparent and unequivocal public information about the regulatory processes, and to ensure the public communication of risk, whether in relation to human health, food, feed or environmental safety is accurate and proportionate. This is imperative to strengthen public confidence in the regulations which address these issues, and the science behind them.

2.   Whether public opinion has moved on since the Committee last considered the issue in 1999-2000—are people more willing to accept GM foods and crops?

  Certainly one can point to recent public opinion surveys which suggest that public hostility towards GM foods and crops is not as universal as it is often portrayed.

  Earlier this year, the Food Standards Agency reported in the findings of its second annual consumer attitudes survey that:

    "In 2001, there were significant drops in the level of concern over the safety of eggs (from 26 per cent in 2000 to 21 per cent in 2001), dairy products (30 per cent in 2000 to 25 per cent in 2001), and foods with genetically modified ingredients (27 per cent in 2000 to 21 per cent in 2001)."

  An NOP survey conducted for CropGen in Spring 2001 suggested that 48 per cent of consumers would eat food if they knew it was GM or contained GM ingredients, against 44 per cent who would not and 8 per cent don't knows.

  The recently established agricultural biotechnology council also commissioned research which showed that more than half of people surveyed would be more likely to accept GM foods and crops if, for example, the technology resulted in more targeted use of pesticides, if the products were clearly labelled, and if GM crops supported environmental benefits, such as an increase in farmland bird populations. But the overwhelming conclusion of the abc research was the public's need and desire to be better informed. Two-thirds of people felt they did not know enough about GM foods.

  From SCIMAC's perspective, however, perhaps the most immediate way to gauge the development in public attitudes is through the local response to individual trial sites. It is important to set the relatively small number of sites which have encountered local protest and opposition into context against the vast majority of trial sites which have proceeded smoothly, often with significant local support. Requests for public meetings in the wake of successive rounds of plantings have certainly fallen since the first year of the trials. This year one Parish Council even took the trouble to write to their local MP to express their support for the trials. And at a Parish Council meeting just last night (Monday 15 April) at Frampton Cotterell in South Gloucestershire, parishioners voted in favour of the trial.

  These are clearly anecdotal examples, but do suggest that the temperature may be coming out of the debate, certainly in relation to the trials themselves.

3.   AEBC report "Crops on Trial" described the Farm-Scale Evaluations as a "cooling off" period—do you agree?

  Neither agree nor disagree. We would view it in different terms. The Farm-Scale Evaluations are an important programme of ecological research in which industry has voluntarily put its technology out to independent scientific scrutiny—over and above any regulatory requirements. No other agricultural technology has ever undergone such a comprehensive programme of testing and evaluation, and SCIMAC's overriding objective within that process is to ensure the successful completion of the research.

  The agreement between SCIMAC and Government which established the basis for the Farm-Scale Evaluations is a measure not only of the industry's confidence in the technology, but also its commitment to ensuring the public is able to make informed judgements, based on independent scientific information. If that process has brought about any constructive change in the level or nature of the public debate during the period of the Farm-Scale Evaluations, then clearly it is welcome, but as a consequence rather than as an objective of the programme.

4.   Question regarding alleged contamination of non-GM crops

  SCIMAC is not aware of any incidents in which the non-GM status of neighbouring crops, whether organic, seed or other, has been compromised as a result of the farm-scale evaluations. This is a measure of the precautionary and scientific basis on which the SCIMAC approach has been developed, combining practical experience and evidence of worst case scenarios as a benchmark to reduce any potential cross-pollination to an absolute minimum within a practical farming situation.

  As the Committee advised in its last report, we will continue to be responsive to new scientific evidence and information in developing the Code—indeed since the Committee's previous inquiry SCIMAC has agreed two minor changes to the separation distances, in the case of forage maize which has been increased from 50 to 80 metres, and between GM oilseed rape and neighbouring crops of Varietal Associations and partially restored hybrids, which has been increased from 50 metres to 100 metres. Both changes were based on the scientific review conducted by NIAB and published in August 2000.

5.   What is the SCIMAC response to the recent English Nature report on gene-stacking in Canada and EN's suggestion that the SCIMAC guidelines are inadequate to prevent gene-stacking in the UK?

  This is an interesting question, given the apparent discrepancy between the EN press release announcing the report:

    "Our report shows that the SCIMAC code is probably inadequate to prevent gene-stacking happening in Britain, if these crops were commercialised."

  and the relevant passages in the report itself:

    "UK organisation SCIMAC have issued guidelines that address the specific on-farm issues raised in relation to HT crops. . ."

    "The SCIMAC guidelines include separating a HT crop from other oilseed rape crops by at least 50 metres. Both UK gene flow data and Canadian experience suggest that this would be effective in reducing significantly the occurrence of gene flow to other canola crops that are not varietal associations or possible partially restored hybrids, and perhaps both the practicalities and the data suggest that there is little benefit in aiming for a greater separation distance."

  It is puzzling that English Nature have chosen to highlight Canadian research when English Nature themselves repeatedly argued that the different agricultural, climatic and geographical conditions in other parts of the world could not be used to inform decisions about the impact of growing GM crops in the UK. Indeed the unique FSE trials were set up in response to English Nature's concerns to assess biodiversity impact in a specific UK context.

  Within the SCIMAC guidelines, action to address any potential problems in controlling volunteers is not just covered through the application of separation distances, but comprises a package of measures from pre-harvesting measures to optimise evenness of maturity, harvesting procedures, post-harvest cultivation, as well as volunteer monitoring and control throughout the rotation.

  SCIMAC is confident, and the English Nature report appears to confirm, that the combination of these measures will prove effective in controlling the incidence of volunteers and minimising the potential for "gene-stacking".

  It is also worth noting that no GM crops have yet been fully cleared for commercial cultivation in the UK. The potential development of multiple herbicide tolerance, or gene-stacking, is an issue considered in detail by the regulatory authorities, who will not approve GM crops for commercial cultivation unless satisfied that there will be no adverse effects on the environment. English Nature is a statutory consultee in that process.

  All non-GM crops currently grown commercially are tolerant to a large number of herbicides. GMHT adds one more to the list—it does not make the GM crop resistant to alternative herbicides or methods of weed control. Volunteers of GMHT rape will continue to be as susceptible to conventional methods of weed control—cultural, mechanical and chemical—as conventional varieties.

  A 10 year study of research conducted by scientists at Imperial College, published last year, effectively dismissed concerns over the development of so-called GM superweeds, concluding that these crops were no more likely to survive or persist than their conventionally-bred equivalents. A similar conclusion was reached in a 1999 review of the environmental risks associated with herbicide tolerant GM oilseed rape commissioned by the former-DETR.

6.   SCIMAC response to Nature article about GM contamination of landrace maize varieties in Mexico.

  SCIMAC can add little to the recent conclusions of the Advisory Committee on Releases to the Environment which, in addition to concerns raised about the testing methodologies involved, advised that long-range cross pollination was an unlikely explanation for the detection of transgenes in landrace maize in remote areas of Mexico.

  ACRE concluded that the simplest explanation was that imported GM maize seed destined for human consumption had been deliberately mixed by Mexican farmers with the local seed for their crops. ACRE categorically stated:

    "Therefore this work does not have any implications for the separation distances used in the UK GM maize farm-scale evaluation programme."

  Furthermore, SCIMAC notes that complaints about perceived flaws in the authors' experimental procedures have led the editor of Nature magazine to conclude that the paper should not have been published.

7.   Farm-Scale Evaluations—what has been learned?

  Within the Government's programme of GM crop Farm-Scale Evaluations, the SCIMAC guidelines have been applied within a normal farming situation at more than 180 field-scale sites across the UK. This experience has demonstrated that the protocols are workable in practice, robust in safeguarding the integrity of GM and neighbouring non-GM crops (including certified seed and organic crops) and capable of being audited.

  In its previous inquiry into the issue, the Committee concluded that the SCIMAC approach "offered a firm basis on which to build in order to segregate GM and non-GM crops in the UK countryside". Our experience of applying the guidelines in practice has borne out that analysis.

  No data or results will be published until the Farm-Scale Evaluations have been completed. This was agreed at the outset of the programme. Clear timescales for the completion of the programme and provision of advice to Ministers are set out in the written agreement between SCIMAC and Government.

  It is imperative that the results of the programme are placed in the public domain and made available to the relevant advisory committees as soon as is practicably possible. The Scientific Steering Committee overseeing the programme has been asked to provide advice to Ministers on a single question—that of comparative impact on farmland biodiversity. It is vital that the conclusion of the trials and publication of data take place in line with the original agreement, and are not delayed unnecessarily or used as the basis for denying regulatory progress in other, unrelated, areas.

8.   Separation distances—AEBC report "Crops on Trial" calls for "adequate separation distances"—how does SCIMAC respond?

  SCIMAC shares the AEBC's concern to ensure that adequate arrangements are in place to promote mutual co-existence between GM and non-GM crops, and to accommodate the interests of all parties. The SCIMAC stewardship programme, which includes crop-specific separation distances, was established to support the effective integration of GM crop technology alongside other farming systems.

  The separation distances specified by SCIMAC aim to reduce the potential for cross-pollination to an absolute minimum within a practical farming situation. These distances are based on well-established scientific knowledge of the characteristics of each crop species in terms of pollen distribution and gene flow, as confirmed in a Government-commissioned review of scientific literature conducted by NIAB in 2000.

  SCIMAC notes that the AEBC report referred to "adequate" separation distances which will allow current organic standards to "continue to be maintained." The report separately noted that after two years of the three-year FSE trials programme, not a single grower's organic status has been affected. This is an achievement on which all parties must seek to build.

9.   Crops on Trial" also suggested that the FSEs had been conceived and designed in a secretive way, with key stakeholders (eg local people, organic farmers, beekeepers etc) not fully engaged. How does SCIMAC respond?

  Firstly there are simply no grounds to suggest that the FSEs were conceived or designed in a secretive way. The former DETR issued a public consultation on the design, methodology and objective of the trials at the very outset.

  SCIMAC remains committed to the principles of openness and transparency within the FSE programme. That's why, for example, consent-holders within SCIMAC took the voluntary step of disclosing precise locations for forage maize sites in 2000 and 2001, and of providing early publication of site locations—in both cases going further than the regulatory requirements for site notification.

  However, it is also necessary to strike a balance between the legitimate ability of researchers and industry to conduct the trials safely and in accordance with the appropriate regulatory framework, and the need to keep local people informed. Selection of trial sites must continue to be carried out on a scientific basis.

  Throughout the process, SCIMAC has continued to seek improvements in arrangements for providing information about the trials and to give local people an opportunity to find out and comment on what is happening in their area. This has applied to successive rounds of plantings, and will continue to apply where possible within the scientific and agricultural parameters of the programme.

  In particular, SCIMAC has:

    —  promoted early consultation between trial growers and their farming neighbours; and

    —  sent information about individual trials to Parish Councils, District Councils, County Councils, local MPs and MEPs, as well as beekeepers' organisations.

  For this year's FSE plantings, SCIMAC has provided six weeks' notification of trial sites, in line with the AEBC's recommendation. This has certainly added to the pressures of delivering the programme on target, but is a signal of our commitment to the principles of openness and transparency on which the FSE programme is based.

  Current GMO regulations require 15 days' public notification—no notification at all in the case of forage maize. Charges of secrecy ring somewhat hollow against the efforts we have made to support transparency and openness within the programme.

10.   How does SCIMAC respond to the AEBC's concern at the "particularly unfortunate" location of some of the chosen sites?

  SCIMAC is concerned primarily with meeting the scientific conditions and objectives of the FSE programme. The term "particularly unfortunate" has little relevance in this context provided it meets the scientific criteria of the research. As previously stated, SCIMAC has made significant efforts—over and above any legal requirements, to ensure details of the FSE sites are made public as soon as is practicably possible within the scientific and agricultural conditions of the programme. Out of the 250 or so sites either completed, under way or planned this year, the vast majority have proceeded without major issue.

11.   Regulatory and advisory framework—how are new bodies, such as AEBC, Food Standards Agency, helping the situation?

  SCIMAC welcomes the role of the Food Standards Agency in providing independent, transparent and science-based advice on food and feed safety issues, as part of the information required by Government to carry out their statutory responsibilities in relation to the regulation of GMOs.

  SCIMAC also recognises the important role of the AEBC in providing a forum for exchange of views and advice to Ministers on the many diverse issues surrounding GM technology. SCIMAC welcomed the Commission's "Crops on Trial" report as an important contribution to the debate, and has acted upon many of the Commission's specific recommendations in relation to the voluntary programme of Farm-Scale Evaluations.

  However, AEBC's role in relation to the regulatory framework which governs GMOs is less clear. Government has repeatedly made it clear, most recently in its response to the AEBC report "Crops on Trial", that the decision-making processes which govern the approval or restriction of individual GM crop applications will continue to be evidence-based. While there is an important general requirement to consider ethical and socio-economic issues, and to consult widely with the public, "consents for the release and marketing of GMOs can only be prevented on valid safety grounds supported by sound scientific evidence." This point is reiterated several times in the Government response:

    "Although general ethical and socio-economic implications of the marketing of GMOs may be taken into account in reviewing the operation of this legislation, the criterion for taking decisions on individual applications is the avoidance of adverse effects on human health and the environment." [paragraph 13]

    "Under the Directive consents for the release and marketing of GMOs can only be prevented on valid safety grounds supported by sound scientific evidence". [paragraph 20]

    "Any eventual decision on commercialisation will be taken using the criteria in Directive 2001/18, which requires more by way of consultation with the public on applications for approval. However the decision-making process will continue to be evidence based." [paragraph 34]

  It could be argued that two, three or perhaps even five years ago a body such as AEBC would have contributed more significantly to the direction and nature of the public debate. From SCIMAC's own experience, there are clear signs that the debate is on the move, and that the degree of hostility towards or rejection of the technology is by no means as universal as is often portrayed.

  AEBC must therefore guard against a situation in which, by its very existence and the nature of its membership, it serves to perpetuate tensions in the debate rather than to work constructively towards consensus positions or to reflect the genuine extent of public concerns. In this respect, SCIMAC would welcome re-clarification of the AEBC's role and remit.


22 April 2002

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