Supplementary letter from Greenpeace UK
With respect to the current enquiry, you were
kind enough to send the paper on "Gaps in the regulatory
oversight of biotechnology in the US" [not printed]
prepared for the committee by Dr Kinderlerer,
and you asked for any comments. Thank you for letting us see this.
While generally agreeing with Dr Kinderlerer's analysis, we do
have some comments.
Probably the first point to make is that although
there has been public criticism of the EU system by both US interests
and the genetic engineering industry, the US system has been subject
to criticism itself in the US by public interest groups (see,
for example, Peril amidst the Promise, Union of Concerned Scientists,
Further, harmonisation of the two systems, if
indeed that is desirable, should not be blind to the deficiencies
of both. Neither system explicitly addresses the handling of uncertainty
that is inevitably present with any new technology, especially
when dealing with biological systems and ecosystems which are
both complex and poorly understood. Whilst at least the EU legislation
pays lip service to the "precautionary principle" the
latitude with which this has been interpreted in practicefor
example in the consent given to the Novartis Bt maize
means that this is not guarantee of precaution in practice.
The nature of uncertainty, and indeed factors which are for all
practical purposes unknowable, means that neither system takes
as an approach "proof of safety" which Dr Kinderlerer
states as being the rationale for the EU legislation in his final
Neither of the US or EU legislative systems
manage to answer the crushingly obvious (to members of the general
public) questions which are required to justify these unknown
risks, and some of these questions are outlined in our evidence.
In summary they include:
Do we need genetically modified foods?
Who benefits and who has to take
Is this the direction in which we
would want to take agriculture?
What will be their cumulative effect?
The way the current EU regulations operate is
that it is taken for granted that GM crops and GM food are good
things unless some specific safety problem is identified in the
(industry's own) tests. All the above questions, and many others,
are left unasked, and certainly unanswered.
We will shortly forward a written submission
we have made to the Environment Minister, Michael Meacher about
the revision of the Deliberate Release Directive 90/220.
Should you wish us to elaborate on the above
please do not hesitate to let us know.
Dictated by Peter Melchett,
Executive Director, Greenpeace UK,
and signed in his absence
26 June 1998
20 Specialist Adviser to the Committee. Back
The Novartis Bt maize is the first genetically engineered crop
to be planted in Europe. an analysis of how this crop came to
be approved, how undemocratic the approval system is, how inherently
not precautionary the system is, and how yawning gaps in policy
were exposed by the approval process, makes interesting reading.
I have enclosed a case study of the process by Greenpeace European
Unit. (Not printed) Back