Select Committee on European Communities Second Report - Written Evidence

Memorandum by Co-operative Wholesale Society


  1. We are concerned that there are gaps in the statutory arrangements for the authorisation and regulation of genetically modified organisms (GMOs).

UK Regulation

  2. In the UK there are several committees concerned with different aspects of the regulatory/authorisation process; the Advisory Committee on Releases into the Environment (ACRE), the Advisory Committee on Novel Foods and Processes (ACNFP) and the Food Advisory Committee (FAC). Each has its own, specific remit. Members are discouraged from discussing issues outside the remit of the particular committee even where such issues fall outside the authorisation process.

  3. In particular, the ACNFP and FAC focus exclusively on use for human food. The question of animal feedingstuffs is largely beyond their remit. So, for example, the FAC considers labelling aspects from the viewpoint of use of GMOs directly in human foodstuffs. They do not consider labelling aspects of animal feedingstuffs nor of the human foodstuffs derived from animals fed GMOs.

  4. The committees are all wanting in that they consider each GMO in isolation concentrating on a particular product. This does not provide a forum for looking at the overall impact of GMOs. For example, the safety of a particular modification is assessed but no account is taken of similar modifications and the overall impact they might have. For example, there is no official check that would prevent every crop being genetically modified to be resistant to the same pesticide/herbicide. Such a development would be a potentially disastrous scenario in that it would place too much reliance on that particular pesticide. Serious consequences could result from the development of strains resistant to that pesticide. Similarly, if the safety of that pesticide was subsequently brought into question, it would have a devastating effect on food suppliers.

  5. Similar criticisms can be applied to European and World-wide regulations.

European Regulation

  6. The European regulatory process gives greater cause for concern with its emphasis on compromise rather than judgment of the scientific facts. We are thinking particularly of the judgment with regard to Novartis (Ciba-Geigy) maize containing an antibiotic marker. The UK regulatory process, quite rightly in our opinion, identified a slight risk with this antibiotic marker from which they concluded it was prudent to prevent its inclusion in animal feeds in the raw state. Three European committees debated the issue. Their deliberations were largely inconclusive, yet the UK decision was overturned.

  7. The European regulatory process is highly bureaucratic. This may be effective in reaching decisions. It is not necessarily effective in reaching the right decisions. It is also very flexible and therefore inappropriate for a fast moving field such as this where what is right one day may be found inappropriate at a later date. This is especially true in the field of consumer information where we are at one point considering the introduction of a new technology but, in time, it has the potential to be commmonplace. Indeed, potentially it could be the non-GMO of which the consumer needs to be informed. We do not have confidence that the European system could accommodate such a shift in opinion/approach.

World-wide Regulation

  8. Biotechnological innovation and the development and bringing to the market of GMOs is costly. There is therefore much at stake if a company's application is at risk of being rejected. A country's prestige is also, potentially, at stake particularly where Governments have invested heavily in biotechnology research. These very real pressures also call into question the thoroughness and adequacy of the regulatory process.

  9. World-wide the approach of considering each GMO application in isolation and to different criteria is of even greater concern, particularly from the viewpoint of world trade. What is deemed safe/acceptable in one country may not be considered so in another yet there are no mechanisms to contain GMOs within the country in which they are approved. Differences in approaches to labelling make for further complications.

  10. This is further exacerbated where GMOs are co-mingled with their regular counterpart. This does appear to be a prime example of something which has slipped through the regulatory net without due consideration of the potential ramifications. Clearly co-mingling of an internationally traded crop by a major producer effectively precludes any other regulatory system reaching a different conclusion on safety, etc. It compromises any labelling commitment. It may, of course, be perfectly justified and any concerns may be esoteric. Something may, in the course of time, emerge which questions the original approval. If this pinpointed a safety risk with the particular GMO it would be impossible to react; to remove it from the marketplace without the removal of all, or all but small amounts of identity-preserved sources of the product in question. This could have catastrophic consequences in the case of a staple food such as wheat.

  11. World-wide there are also concerns that conditions of approval linked to an authorisation in one country may not be applied in a second or third country. What is seen as a benefit in developed countries may be assumed to be a panacea for exploitation in third countries where the ability and expertise to instigate such controls is wanting.

  12. In addition to wilful exploitation of GMOs throughout the world, the question of uncontrolled expansion should not be forgotten. Crops, and even animals, on their own will not respect borders. There is therefore a feeling of uncertainty as to ultimately how GMOs can be controlled world-wide.

  13. These concerns lead us to the belief that there must be international regulation and harmonisation.


  14. Labelling goes hand in hand with regulation. As with regulation, there must be international harmonisation. The arguments parallel these detailed above with labelling policies in one country being dictated and/or compromised by different policies in another country.

  15. The question of so-called substantial equivalence and co-mingling is the fundamental issue in this compromise. As indicated above, where a country permits co-mingling it precludes any other country receiving co-mingled sources from accurate labelling. Indeed, any material which is not labelled at source can not be subsequently labelled with confidence. There must be traceability of GMOs from sowing to final product. This labelling is reduced to the least onerous policy within the chain.

  16. At the present time it is not at all clear to what extent products of GMOs should be labelled. There has been an assumption that only materials containing modified DNA and/or protein need to be identified. This philosophy supports a policy of monitoring the impact of such changes on, for example, diet. It does not, however, address the wider concerns of the consumer who wishes to avoid products downstream which have an environmental impact upstream.

  17. Labelling and traceability are essential if there is to be any form of monitoring the long-term consequences.


  18. This is a new technology and there has been a recognition of the need to monitor its impact both in the wider sense of its environmental impact but also from the viewpoint of product safety.

  19. Safety evaluation is only as good as the tests applied. Long-term consequences of GMO consumption may emerge. The science of insertion of GM material is acknowledged to be imprecise and may, in certain cases, result in a change to a particular food or ingredient which results in an adverse reaction or changed nutritional value adversely affecting expected dietary intakes. It has to be recognised that each, individual, modification of a particular commodity is unique. It is therefore potentially not merely a case of tracking GM soya but of a need to look at each individual GM soya. Such impacts may not be immediately apparent but may emerge only from long-term dietary studies of populations. It is therefore important to monitor the consequences of such long-term exposure.


  20. A major concern with any technological innovation is whether it offers advantages which benefit society or whether it merely pushes back the frontiers of science. There are greater concerns with the introduction of a technology which is not confined to specific, discrete areas but which promises to be all pervasive throughout the animal and human food chain and throughout agriculture. It is therefore worrying that there appears to be no overall co-ordination of research.

  21. First and foremost, with the development of such a technology it would have been beneficial to involve recipients (consumers) of the technology before it was forced upon them in an uncontrolled way in the marketplace. It is appreciated that, without real-life examples, it is difficult to involve ordinary consumers. There are, however, some fundamental issues which could have been elucidated, for example, the question of traceability.

  22. As indicated above, there is a lot at stake commercially from the exploitation of GM research. It is important therefore that there is some certainty in the regulatory outcome if a research programme is successful. It is therefore of concern that through this lack of co-ordination later developments in a similar field may be rejected because of concerns of proliferation. We are thinking particularly of the concerns raised with regard to over-use of individual pesticides.

  23. We are equally concerned that there seems to be no detailed consideration of the acceptability and overall consequences of research techniques. We are thinking of the use of antibiotic markers, a perfectly acceptable research technique but with long-term and wider implications when considered in the context of antibiotic resistance. This is not a new phenomenon which has emerged since the development of the early GMOs. It has been an issue for decades which has come to the fore in this decade. In view of the commercial drivers it is worrying that there is apparently no system which would highlight unacceptable techniques such as these. If their use could not be prevented, at least the likely consequences of non-authorisation could be flagged up, thereby highlighting the commercial risks of pursuing such a course.

27 May 1998

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