Select Committee on European Communities Minutes of Evidence


APPENDIX 4

CODE OF PRACTICE ON THE PROVISION OF INFORMATION RELATING TO GENETICALLY MODIFIED CROPS

INTRODUCTION

  Modern plant biotechnology extends the scope and precision of conventional plant breeding. Techniques such as genetic modification (GM) offer significant improvements in crop production and utilisation, with benefits to agriculture, the food industry, consumers and the environment.

  The provision of information relating to genetically modified crops will play an important role in ensuring best practice is adopted by all those involved in the production, handling, storage, processing and marketing of these products.

  An effective information delivery system along the food supply chain for UK-produced GM crops is also needed to provide consumer choice and satisfy consumer demands for information about the use of GM in food production.

  This Code of Practice has been developed to establish a consistent, industry-wide approach to information supply for GM crops from seed to primary end-product. This will provide the information required by those further along the food chain to manage storage and processing operations effectively, to conserve the value of the harvested commodity and to ensure appropriate record-keeping and onward transfer of information.

THE FOLLOWING BASIC PRINCIPLES SHALL APPLY:

  All GM material entering the food chain must comply with legal requirements relating to environmental release, marketing consent and food safety.

  All parties must take reasonable steps to ensure that the information provided is accurate and presented in a clear, concise and readily understood format.

  This Code of Practice will be subject to annual review.

INFORMATION REQUIREMENTS

  Plant breeders are required to identify and provide comprehensive information relating to GM crop varieties to comply with the requirements of statutory trials within the EU. This information is publicly available through independent published sources such as the EU Common Catalogue and national recommended and descriptive lists.

  To ensure best practice across all sectors of the industry, and to provide traceability for individual consignments of GM varieties, the consenting parties (BSPB, NFU, UKASTA) recognise the need for successive transfer of supplementary information at strategic points along the food chain:

    —  by seed merchants: to market GM varieties and advise growers of the unique features of the material;

    —  by growers: to manage seed handling and crop husbandry effectively, to ensure appropriate record-keeping and storage arrangements and to market the harvested crop;

    —  by merchants and wholesalers: to ensure appropriate record-keeping and transfer of information during storage and onward distribution.

  To comply with the requirements and objectives of this Code of practice, the licenser of the GM technology and/or developer of the variety should ensure that the following information is available to growers—either directly or via the seed supply trade—in relation to each GM crop variety:

    The variety is genetically modified

    The nature of the modification(s)

    Specific husbandry and management advice

INFORMATION TRANSFERSEED SUPPLIER TO FARMER

  A combination of communication routes will be required to ensure that the necessary information is available to the relevant personnel and in an appropriate format at each stage in the seed marketing and primary production process:

1. Variety Guides

  Independent UK variety guides will identify which varieties have been developed using genetic modification and, in each case, the nature of the modification(s).

2. Marketing Literature

  Commercial sales and marketing material produced by the licenser of the GM technology and/or the developer of the variety should state clearly that a variety has been developed using genetic modification and the nature of the modification(s). It should also provide basic advice on good husbandry and farm management practice, particularly where this differs from conventional crops, as well as details of where further advice can be obtained (e.g., Information Helpline).

3. Seed leaflet

  All growers purchasing GM seed should receive an explanatory leaflet stating clearly that the variety has been developed using genetic modification and the nature of the modification(s). It should also provide basic management advice relating to handling, storage and transportation of the seed, as well as details of where additional management and husbandry advice can be obtained (e.g., Information Helpline).

4. Seed package identifier

  A visual identifier, exclusive to GM varieties, should be clearly displayed on the label of each package of GM seed. This will help to ensure that the seed is handled and stored on-farm according to best management practice, and to inform farm personnel that supplementary management and husbandry advice is available.

5. Information Helpline

  The licenser of the GM technology and/or developer of the variety should provide a telephone information service to answer specific requests for more detailed information from growers and/or the seed supply trade relating to the product and its use.

GOOD AGRICULTURAL PRACTICE

  To comply with the requirements of this Code of Practice, each GM crop should be identifiable by variety at all stages, from initial seed stock through production, harvesting and storage.

  The importance of good agriculture practice, including record-keeping and segregation of varieties, is recognised by growers as a vital component in meeting the quality assurance demands of the food industry and, ultimately, of consumers.

  The NFU will continue to communicate the importance of record-keeping to its members. Other information supplied to farmers in relation to GM crop varieties should also highlight the significance of record-keeping in safeguarding the value and integrity of the harvested commodity, and in transferring information further along the food chain.

  Basic guidelines for good agricultural practice when growing GM crops with specific agronomic traits should be encouraged. Summary guidelines, where developed, should be followed in combination with variety-specific information.

INFORMATION TRANSFEREX-FARM

  When transported off the farm to the merchants and wholesalers, each GM crop consignment should be accompanied by a post-harvest declaration which should include the name of the variety.

  The provision of such information should be maintained during subsequent transportation of consignments. Those involved with GM crops post-farm should address the issues of continued transfer of information and traceability of such crops. In addressing these and other points attention should be paid to the basic principles contained within this document.

INFORMATION FLOW FOR UK-GROWN GM CROPS

  The flow chart below identifies the strategic points along the crop-based food supply chain at which information transfer will be required to ensure the aims of this Code of Practice are fulfilled. The boxed section illustrates the role of this Code of Practice, which fulfils the information requirements of the primary supply chain from seed supplier to primary end-product.

  Organisations further along the food chain, from primary processors to food retailers, are encouraged to ensure that the successive transfer of information is maintained. This will enable the industry to comply with statutory food labelling requirements, and to provide supplementary consumer information on a voluntary basis.


CODE OF PRACTICE TO ESTABLISH A CONSISTENT APPROACH TO PROVIDING INFORMATION TO FARMERS AND GROWERS REGARDING GENETICALLY MODIFIED CROPS

January 1997 (Revised June 1997)

  This document has been drafted by the National Farmers' Union following consultation with the British Society of Plant Breeders.

  The aim is to encourage best practice among farmers and growers who choose to grow genetically modified crops. In order to achieve this it is imperative that they receive sufficient pertinent information about these new crops.

  This code of practice seeks to ensure that a consistent approach to provision of information is adopted by the seed supply industry. It details the type of information that should be provided to farmers and growers, and how that information is best communicated.

  There is also a clear need for consumer information regarding food containing genetically modified material. Food Labelling will play an important part in informing consumers and providing consumer choice. Labelling food products will be on a statutory and voluntary basis. It is essential that an effective information supply system is provided all along the food chain from primary producer to the retail point of sale. This code of practice seeks to ensure that this information system is in place.

CODE OF PRACTICE TO ESTABLISH A CONSISTENT APPROACH TO PROVIDING INFORMATION TO FARMERS AND GROWERS REGARDING GENETICALLY MODIFIED CROPS

National Farmers' Union

1. Introduction—The need for information

  The National Farmers Union and the British Society of Plant Breeders have recognised that the appropriate use of genetically modified crops will be the responsibility of farmers and growers. They therefore need to receive sufficient pertinent information, to ensure that they are sufficiently informed of how to use the products and are aware of any necessary changes to farm management practices.

  Provision of clear, relevant information along the food chain is necessary to ensure that food businesses can fulfil their food labelling obligations (whether statutory or voluntary). This will require a continuous information supply chain from plant breeders and seed merchants, to farmers and growers, merchants and wholesalers and retailers.

  A consistent approach by industry is highly desirable, especially in the early years of commercialisation of genetically modified crops varieties. The adoption of this code by the seeds industry will ensure that the benefits of this new technology are realised, and that confidence in its safety is gained.

2. Who needs information on the farm?

  Information is needed at three levels in farm operations:

    (i)  The manager or owner, who is responsible for cropping policies, making the seed purchasing decisions and selling the final crop on to their customers;

    (ii)  The unit manager who is organising the implementation of the cropping programme and takes possession of the seed;

    (iii)  The operator who will be undertaking the day to day operations.

3. What information is needed?

    (i)  Farmers and growers need to know that the seed is genetically modified. This will ensure that information which may be required by the end consumer, is available throughout the supply chain. It may be necessary to label the end food product to identify that it contains genetically modified material. This information must therefore be available at the point of primary products so that it can be passed onto customers and ultimately to the final consumer.

    (ii)  Farmers and growers need to be informed of the nature of the modification. This will ensure that the farmer is able to make an informed decision when purchasing seed, and to provide information to allow him to make any necessary adjustments to farm management practices.

    (iii)  Farmers and growers may require further advice on good farm management practice. For certain genetically modified products, such as herbicide tolerant crops, or crops modified for industrial purposes, special management conditions may be required. Clear advice on any necessary changes to farm practices is needed, including why such changes are necessary, and what problems might occur if these changes are not implemented. Advice should cover management of potential volunteer problems, minimising cross-contamination both in the field and in storage, and accidental spillage during haulage.

    (iv)  Farmers and growers should be made aware of the importance of record keeping. Long-term record keeping will become increasingly important with the introduction of genetically modified herbicide tolerant and "designer" oil crops. This will be particularly important where farms or parcels of land are managed on short-term contracts. The importance of record keeping, to minimise problems in the future, needs to be highlighted by the supplying companies.

    (v)  Farmers and growers may also require supplementary information and advice on management practices. Companies supplying genetically modified crops should offer their customers an additional information and advice service.

4. How should information be communicated?

  A combination of communication approaches will be needed to ensure that the appropriate farm personnel receive sufficient, pertinent information that is easily understood. The necessary communication approaches, over and above normal sales and marketing literature, should include:

    (i)  Explanatory information in sales literature and the NIAB handbook. In making a purchasing decision, a manager or owner will be relying on information provided by commercial marketing material and the NIAB handbook.

    (ii)  Explanatory information in a leaflet accompanying the seed. The unit manager and the operator will rely on the information provided with the seed.

    (iii)  An identifier on seed sacks. An identifier on the seed sack is necessary to alert farm personnel to the supplementary information, and to ensure that farm operators do not unwittingly mix genetically modified and conventional seed before sowing.

    (iv)  An information help-line. While making a purchasing decision, or making adjustments to management practices, a farmer may require supplementary information and advice. A telephone information service should be provided by product suppliers.

      The information provided ((i) and (ii) above) should not be too detailed. It does not need to offer in-depth "best-practice", merely to alert all concerned to any differences from conventional crops, and any adjustments to management practices that are necessary. More detailed information can be provided to farmers through an information "help-line".

5. The information required

  The necessary information should be communicated to farmers and growers as "good farm practice".

    (i)  Good Farm Practice. Farmers must be aware of the nature of the modification, and be aware of any special management practices that might be necessary.

      The use of crops genetically modified for herbicide tolerance will inevitably lead to herbicide tolerant volunteers in subsequent crops. They may persist for many years after the crop has been grown commercially. Farmers must be aware of any possibility and be provided with management advice on how best to minimise possible problems.

      Advice should cover seed handling, storage and transportation. The importance of segregation from conventional varieties and the need for due diligence should be highlighted.

      Long-term record keeping will become increasingly important as farmers use crops genetically modified for herbicide tolerance and for industrial uses. For example, oilseed rape can remain in the soil for 10 or more years after the commercial crop is grown. Volunteers from an oilseed rape crop, genetically modified to produce an industrial oil, could lead to accidental cross contamination of oilseed crops grown in subsequent years, in the same, or adjacent, field.

      It is therefore important that farmers record the location and nature of such crops, so that future cropping and treatments can be planned effectively. This will ensure that any potential cross contamination between oilseed rape crops can be avoided. Long-term records will be particularly important where land is farmed on a short-term contract basis. It is clearly in a farmer's interest to keep records and the need to do so should be highlighted as an integral part of "good farm practice" rather than as something additional.

      The importance and relevance of long-term record keeping should be included in the explanatory information accompanying the seed, and in the NIAB handbook. The NFU will also play a role in highlighting the importance of record keeping to NFU members.

    (ii)  Information help-line. By providing a telephone information service to farmers and growers, supplying companies will ease product introduction and help build understanding and confidence in the product and the technology in general.

      Farmers may require more detailed information via a telephone help-line prior to making their purchasing decision, and after they have received the seed. The telephone number for any help-line service provided should be prominently displayed on marketing literature and on explanatory information accompanying the seed. We encourage supplying companies to provide this type of information service to farmers and growers.

    (iii)  Labelling Seed Pack. It is important that an identifier is used on the seed package itself, in order to inform the farmer/farm operator that the seed is different from conventional varieties. It should also alert him to the accompanying information.

      The identifier should be simple and consistent across different species and varieties. It should be located on the official section of the official label.

      Further discussion is needed to determine the most appropriate identifier. Suggestions include a simple logo, or form of words. Any identifier must be factual, meaningful and should not be misleading.


Source informationIdentifier
on seed sack
NIAB
handbook
Sales
literature
Leaflet
accompanying
seed
Telephone
help-line

The seed is genetically modified3 33
THE NATURE OF THE MODIFICATION 33 3
Advice on good farm practice 33
The need for long term record keeping 33
Detailed additional advice 3
TELEPHONE NUMBER OF HELP-LINE 3 3


GENETICALLY MODIFIED HERBICIDE TOLERANT CROPS

JOINT RESPONSE TO MAFF CONSULTATION

National Farmers Union (NFU)

British Society of Plant Breeders (BSPB)

British Agrochemicals Association (BAA)

United Kingdom Agricultural Supply Trade Association (UKASTA)

British Sugar Beet Seed Producers Association (BSBSPA)

  The organisations listed above believe modern plant biotechnology, including genetic modification, offers major scope for progress in crop production and utilisation. The technology holds significant benefits for farmers, food producers, consumers and the environment. As UK agriculture moves towards a more free and open global trading environment, the advances made possible by this new technology will play a key role in maintaining the viability and competitiveness of our farming and food industries.

  These five organisations, together representing the UK agriculture and supply sectors, recognise the need to demonstrate an open and responsible approach to the introduction and application of this new technology. To promote best practice in the production and use of genetically modified crops, an industry Code of Practice on the Provision of Information relating to Genetically Modified Crops, issued earlier this year, was developed jointly by BSPB, NFU and UKASTA following widespread consultation over a 12 month period.

  This Code of Practice provides for the development of specific guidelines for good agricultural practice when growing GM crops with particular agronomic traits. Together with the Assured Combinable Crops Scheme and the MAFF Codes of Good Agricultural Practice, it therefore offers an appropriate framework within which to address the issues raised in the Ministry's consultation document on genetically modified herbicide tolerant (GMHT) crops.

  The organisations listed above firmly believe that industry itself is best placed to develop practical guidance on the growing of GMHT crops but with a leading government involvement in the promotion and distribution of that guidance. This approach would support the existing comprehensive regulatory framework controlling the development and commercialisation of these products. Such an approach is in line with the Government's deregulatory policy and would allow for a more flexible and dynamic framework, responsive to new developments in the production of these crops either as a result of practical experience or technological advances.

  The industry-sponsored Code of Practice on the Provision of Information has been well-received among potential users and consumers of GM crops and, in consultation with Government and other interested parties, forms a good basis on which to build flexible and appropriate guidance for the cultivation of GMHT crops.

  Plans are already well-advanced to develop industry guidance for the on-farm management and cultivation of GMHT crops. The MAFF consultation exercise provides an opportunity for these guidelines to take account of the full spectrum of views on this issue.

  Areas to be covered should be specific to GMHT crops, with cross-referencing to other documents and codes as appropriate, in particular the MAFF Codes of Good Agricultural Practice, the Assured Combinable Crops Scheme, and the industry-sponsored code on the provision of GM crop information.

  These areas will include:

1. Seed

    (a)  labelling of the seed sack or package, and information contained in relevant accompanying documentation, in particular to ensure that the GMHT variety can be readily identified by the operator to prevent inadvertent herbicide applications to non-tolerant crops;

    (b)  provision of specific husbandry and management information to accompany the seed;

    (c)  clearly identified contact advice points or helplines from which farmers can seek additional information.

2. Production

    (a)  reference to principles of good agricultural practice when growing and harvesting arable crops;

    (b)  guidance on recommended separation distances or voluntary "zoning" arrangements;

    (c)  specific guidance on management of volunteers and outcrossing;

    (d)  specific guidance on management of cropping plans and rotations;

    (e)  guidance on timing of spray applications and/or use of field margin buffer zones.
  (This section will take account of guidelines already prepared by the British Agrochemicals Association covering certain aspects of the production and management of GMHT crops).

3. Record Keeping

    (a)  reference will be made to existing requirements for on-farm record-keeping and any additional data considered appropriate;

    (b)  guidance on format of records, who should keep them and for how long;

    (c)  advice on procedures for transferring records or making information available to others (in the case of short-term tenancies or when contractors are used, the provision of accurate, up-to-date farm records will be essential to ensure the effective management of GMHT crops).

4. Monitoring

    (a)  industry guidance will consider the role of a post-approval monitoring or feedback system, particularly in the initial stages of the introduction of GMHT crops, to assess their performance and to provide early information.

  The MAFF consultation document refers specifically to measures aimed at preventing the development of multiple tolerance in GMHT crops. Practical advice contained in these guidelines to minimise the risk of out-crossing and spread of volunteers will control the risk of involuntary build up of multiple tolerance in the cultivated and non-cultivated environment. The commercial introduction of crop varieties with multiple herbicide tolerance will be subject to stringent regulatory approval before release.

  In developing this guidance, the organisations concerned will take account of any comments received by MAFF in response to the present consultation. It is planned to issue draft guidelines for comment, covering the areas outlined above, by 30 November 1997, with a view to securing final agreement by 31 December 1997.

  Once issued, the guidelines will be subject to annual review, taking account of new developments in the technology, practical on-farm experience and the input of ongoing research and extension projects.

11 September 1997



 
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