Letter from United Nations Industrial
I write further to your invitation to provide
written evidence to Sub-Committee D, in the course of its enquiry
into genetic modification in agriculture, especially with regard
to its regulation by the EC. I should make clear at outset that
I do not have direct involvement in the implementation of the
European Directives governing the environmental release of genetically
modified organisms. However, I do have extensive experience of
the implementation of regulatory frameworks elsewhere in the world.
It is possible that my more general comments, drawing on this
broader experience, will provide a useful perspective upon the
specificities of European legislation.
1. I draw attention to the need to preserve
a degree of national autonomy in the course of implementing frameworks
governing the use of genetically modified organisms, without compromising
the effort to maintain agreed common denominators within European
legislation. This need is reflected in the diversity of national
interpretations of Directive 90/220/EEC, as revealed in a recent
study (see An appraisal of the working in practice of directive
90/220/EEC on the deliberate release of Genetically Modified Organisms,
Working Document for the STOA Panel. Luxembourg, January, 1998).
It is a need that is confirmed by my experience elsewhere in the
2. Whilst harmonisation of biosafety legislation
is desirable in the course of promoting free trade, I would point
to legitimate differences of national interest which may be compromised
in the course of such harmonisation. For example, a concern on
the part of some European countries to critically examine the
possible impact of transgenic crops in the light of a desire to
move towards systems of organic agriculture.
3. In particular, consideration should be given
to the further narrowing of the genetic base and a commensurate
increase in genetic vulnerability following widespread use of
4. The impact of transgenic crops upon the long-term
use of pesticides and herbicides will also vary from product-to-product,
and requires case-specific review.
5. Whilst commercial use of transgenic crops
in the EU is as yet inchoate, it is premature to consider a relaxation
of the regulatory procedures preceding environmental release of
genetically modified organisms. Many of the environmental impacts
of transgenic crops may only become apparent after many years'
use, and it is important that mechanisms are in place for long-term
monitoring of such possible effects.
6. Such relaxation would be particularly inappropriate
in view of the widespread public scepticism of the efficacy of
the regulation of biotechnology, as revealed in the recent Eurobarometer
7. In view of the corresponding public distrust
of scientists, who are increasingly perceived as operating to
political or industrial agenda, it is evident that there is a
need for the strengthening of public involvement in the regulatory
process. I suggest that provisions for public information should
be strengthened, ultimately to provide for public participation
in the regulatory process. Precedents for such public involvement
have been set elsewhere in Europe (in Norway, for example). In
the long-term, such involvement will benefit the biotechnology
industry, through public confidence building.
Please do not hesitate to contact me if you
would like me to elaborate further on any of these points.
George T Tzotzos
4 June 1998